Finance committee  At the moment, there's more information that we're required to collect immediately and provide to the U.S. than they are required to collect immediately.

Finance committee  Well, the intergovernmental agreement achieves a number of different benefits, but on this particular point, the ability to collect information under our own law and provide it to the Canada Revenue Agency and then to transmit it under our own law and the Canada-U.S. tax treaty seems to avoid potential concerns on privacy issues, as well as with—sorry, regulatory issues—whether or not access to basic banking would be a concern.

Finance committee  Forgive me; I'm melding two things. There's the consequence of FATCA versus an IGA, and FATCA itself, in the event of information not being furnished as required under FATCA, could involve account closing. It is not specific to your point about why information is provided to the CRA and over to the U.S. versus directly to the U.S.

Finance committee  Yes, I would say so. First of all, the scope of the information to be provided is narrower under the intergovernmental agreement than under FATCA. Second, the transmission of that information is, under the Canada-U.S. treaty, subject to the safeguards of the treaty and our own laws, which require that it only be used for the purposes of U.S. taxation and not for other purposes, and only if it is relevant to U.S. taxation and not to other purposes.

Finance committee  The tax treaty we have with the U.S. stipulates that the only purpose for which this information can be used is for U.S. taxation, and none other.

Finance committee  I'll make two points. First of all, there is reciprocity in terms of the protection of information. The Canada Revenue Agency and the Government of Canada are subject to the same constraints with respect to the use of tax information that it obtains from the U.S. as the U.S. is in relation to information it obtains from Canada.

Finance committee  Sorry. That would be the right between governments to determine that the other party was in breach of the agreement. Certainly, I think it would cause information to stop flowing, but it could also be cause for termination of the agreement.

Finance committee  No, we do not have a specific estimate. That will depend on the number of citizens who have the type of accounts that fall within the reporting regime and who are not exempted because of the nature of the accounts themselves.

Finance committee  I would describe it as a tax treaty. It's an agreement in relation to an exchange of information, but I think that falls under the heading of treaty, yes.

Finance committee  I would say generally not in terms of a numerical assessment of number of taxpayers affected. When there's a change in the treaty policy, for example, a change in withholding tax rates, that Canada might be willing to offer in most or all of its negotiations, that's something that would be costed.

Finance committee  I think it would depend on what the relative change was as to how many people were affected.

Finance committee  What matters for reporting is U.S. citizenship, which triggers a report, or U.S. tax resident, which means either being a resident of the U.S. according to our general definition of the term or being a U.S. taxpayer by virtue of another heading, which would be citizenship. Whether dual or non-dual, if they are a U.S. citizen, they're potentially subject to reporting.

Finance committee  Yes, and that is by virtue of their U.S. citizenship; that is what matters.

Finance committee  It will depend on whether we're talking about existing accounts or new accounts. With respect to existing accounts, it's much along the lines, at the general level, that you describe. An electronic search is generally the procedure. If the electronic search shows up a U.S. indicator, then that could be the prompt for further inquiry.

Finance committee  Is your question about taxation or is your question about the reporting of the account?