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Finance committee Again, this is not part of the intergovernmental agreement, but it would be a question as to the application of the Canada-U.S. treaties' exchange of information provisions generally. Under those provisions, it's possible for the U.S. to request information that's relevant to the
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee On a request basis again, the postulation?
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee First of all, the question of what would have happened in the alternative matters a lot, we think, but secondly, yes, there is reciprocity. It's not full reciprocity. The scope of information that the U.S. is asking its IGA partners to provide is not being committed to by the U.S
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee It's not to the same degree, although there are some additional points of information that the U.S. has agreed to provide that they can do under their existing law.
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee They are providing some information immediately and they commit to equivalent levels of exchange in the future.
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee Since the last century. I think it was in 1913 that modern citizenship taxation was introduced in the U.S.
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee First of all, I think you're raising a number of important points and I won't be able to do justice to them all in my response, but in the main I would say yes, you are properly identifying the two different things that are sort of running through this file, if I can call it that
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee Yes. I believe that's what the minister said as well.
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee There's not an explicit requirement to that effect. It is the case today in regard to non-residents who receive Canadian-sourced income that the entities making those payments are generally required to submit information returns to the Canada Revenue Agency, and the Canada Revenu
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee I'm sorry, I was seeking to answer that in the second part of my response. A U.S. citizen is not currently subject to any reporting requirement, because citizenship isn't relevant, as residence is, for Canadian tax purposes. Where a person shows a marker of having a U.S. indica
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee Well, it's the legislation that's proposed to be before Parliament that imposes that requirement. But my answer remains that, practically, the U.S. person will be contacted to find out whether there's further information to provide, but there's not an explicit requirement for not
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee Certainly there's a cost to the CRA, which was $5.7 million over five years, if my recollection is correct, and the banks have their own estimates. But we did not speak to that and couldn't speak to that. The question is how the banks will seek to absorb that cost. I don't know t
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee Yes, but I can't speak to the question as to how they will seek to recoup that cost, whether it will be from those involved, or generally.
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee What the CRA does today and, indeed, what the IGA may further enhance, is the ability of the American tax authorities to determine whether a liability for tax exists. That's true. As I say, it's already the case today that this agreement would enhance it in both directions. I don
May 6th, 2014Committee meeting
Brian Ernewein
Finance committee My understanding of what the minister said and of how the rules apply is that FATCA is applicable potentially to U.S. taxpayers, including U.S. residents--according to our concept of the term—as well as U.S. citizens. So a dual citizen could be subject to the application of the i
May 6th, 2014Committee meeting
Brian Ernewein