Finance committee  I don't know of any. To take the specific example you raise, if there's a person who's living in Canada while a green card holder...so they're actually living in the U.S.?

Finance committee  All right. Well, in those circumstances they'd be exposed, if you want to call it that, to the U.S. tax system already. Their income would be subject to U.S. tax by virtue of the U.S. employment.

Finance committee  Not that it occurs to me.

Finance committee  Thank you. Thank you for acknowledging at least that there is this point about issues avoided. I think there also is the point that we do gain some additional information immediately from the U.S. in relation to the collection of taxpayer identification numbers, which will help in our own data matching.

Finance committee  If they are not a Canadian citizen.

Finance committee  It's a very good but very involved question. At a high level I will say this. We already require entities and other taxpayers who are making payments to non-residents to identify those payments and to provide that information to Revenue Canada. When the payment is going to a resident of the U.S., there is already an exchange of information that happens.

Finance committee  It does, so we'll be collecting some additional information from the U.S., particularly in relation to what I've talked about as taxpayer identification numbers. I do want to say though, for completeness, that it's not at the same level at the outset. The U.S. has asked the countries that enter into these IGAs to provide the information that I've talked about, to do the due diligence procedures that I've talked about as well.

Finance committee  We are not talking about individuals alone. We've often, because that's where the conversation has led, talked about U.S. residents and citizens, but there's some relevance to entities as well. If you'd like, we could give you some more information on the entities.

Finance committee  Well, I'll answer that question first, and then if you're still interested we can talk about how the rules work in relation to entities. It's the same restrictions on the use of taxpayer information that I talked about earlier that would apply there. There is a question of reliance and reliability of the foreign country with which we are exchanging information that comes into play on this.

Finance committee  No, that I can't speak to. We have heard that $100 million figure. It was used actually very early on by one or more of the banks as a very rough estimate, but I frankly don't recall any longer whether it was in relation to FATCA, or.... I think it was in relation to FATCA rather than this new model.

Finance committee  Well, I want to be clear, first of all, that I'm not subscribing to the number because I don't know if that is the right number. I also want to make the point that apropos the point that Mr. Saxton made, the scope of the obligations on financial institutions and on their clients is much reduced by virtue of this agreement as compared to what FATCA itself would have required.

Finance committee  I think I can say without any hesitation that it certainly would have been more. This is an obligation on the banks. I've made the point more recently, in another discussion, that I'm sure the banks aren't tickled by this, even with what we have done. I do think they have taken the position and would continue to take the position that this is much less onerous on them than the alternative would have been.

Finance committee  Thank you. This is purely an information agreement, so it's about collecting information from financial institutions and providing that information through the Canada Revenue Agency to the IRS. As to what systems and collection provisions we have with the United States, there is such a provision.

Finance committee  Well, may I be clear, first of all, that I think there are two separate legal questions that may have been bundled up in yours. One is whether or not it's possible for Parliament to enact a law requiring a collection of information, and whether or not by virtue of that law the Privacy Act makes space for it to apply.

Finance committee  The Minister of Justice, as I understand it, has discharged his responsibility to review the legislation and assess it on constitutional grounds, on charter grounds.