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Finance committee  I'm saying that the intergovernmental agreement exempts those accounts from reporting—

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  It's our colleagues at the Canada Revenue Agency that would ask and answer that question. Again, the question would be whether it's relevant to U.S. taxation and the taxes covered by the Canada-U.S. tax treaty.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  They would need to satisfy themselves that the U.S. explanation as to why they were requesting the information was cogent. Yes, I think that's right.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  Is your question, again, about what they've been doing for the past 50 years?

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  I don't believe so. As I say, it's been going on for a long time.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  For a joint account, do we know if the full amount is possible?

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  That isn't the plan. Our general practice with consultation on potential action items is that we'll say that we'll be asking for permission to post them if people are willing to allow that. If they do, it's posted on our Finance website. We generally don't do that with draft legislation, which this was, and haven't in this case.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  No, it applies to the dual citizens if you're talking about the terms of the report under the intergovernmental agreement.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  Yes, the banks are the only ones—well, financial institutions more generally are the ones with the potential obligation to report, and they don't have an obligation to report registered accounts such as the ones you've listed.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  A dual citizen who is a U.S. citizen under one of their—

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  As I say, they've had for a long time already an obligation to comply with U.S. tax law. If that's a taxable item under U.S. tax law, they'd be required to report it.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  Not the contributions per se—

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  My understanding of the question that you raised the last time on grants, particularly from the government, is that under the Canadian tax system those are taxable if and when the grants are paid out to the beneficiary. As I mentioned the last time, from our discussions with the U.S. and our description of the regimes, they suggest that they would not be taxable on contribution to the plan but appear to be taxable by the U.S. as well in the same way we would on payout to the beneficiary.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  Not as part of the IGA, but separately from that, it's possible that on a request for information that could be provided.

May 6th, 2014Committee meeting

Brian Ernewein

Finance committee  Certainly, there's that potential reaction to this tougher enforcement, you can call it, of U.S. citizenship taxation, with people becoming appreciative of the obligation it creates and judging it not worth their while to remain U.S. citizens as a result. I've forgotten the stats, but whatever the baseline was....

May 6th, 2014Committee meeting

Brian Ernewein