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Finance committee That's a function of whether people came to understand they were American citizens or thought they had given it up over time or the like. I'm not aware of any statistics being compiled on that.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee My understanding is that the estimate that's been used includes all persons who are actually American citizens living in Canada. I take it that, whether they are citizens or aware of being citizens or not, they are counted.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Well, it's as I said before. The Canadian position, where the circumstances warrant—where we think the other country is in a position to both collect the information to provide to us and to receive the information and respect its confidentiality—is to consider automatic exchange
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee I think that is fair. To explain the point, the general exchange of information provision in our tax treaties authorizes automatic exchange of information but does not require it. So for any country that seeks to do it with us—and if we're prepared to do it with them—the authorit
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee Thank you very much. I appreciate that I'm sort of an add-on here, so I will try to be brief, but I'm glad that you did return to this point, Chair, because the fact of the matter is that we do have some concerns. Perhaps they're not as grave, but we think they're still materia
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee Thank you. If I may just take one second to make the comment about the reference to the OECD Convention on Mutual Administrative Assistance in Tax Matters, Canada has not ratified that. Canada has not ratified that, because it requires a technical amendment found in Bill C-48, w
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee No, I don't know the answer to this question. The Canada Revenue Agency has that information. We could forward the information to you.
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee I think it is. I believe when I was here last time I made the point that automatic exchange of information is something that Canada supports in principle, but in practice it's quite difficult to do—for example, with a jurisdiction that does not have a tax system and thus does not
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee Thanks, first of all, to the committee for indulging me in appearing here. The answer to the question is, no, I don't believe we were rushed on these matters. As Alain Castonguay explained, the operative standard for exchange of information is on request. Most of our tax treatie
June 17th, 2013Committee meeting
Brian Ernewein
Finance committee Perhaps I might take that. The technical tax bill has a lot in it. I think it is roughly 1,000 pages, most of which are highly technical amendments effectively dating back through the last decade and implementing a lot of changes relieving taxpayers on a technical level. On a l
February 5th, 2013Committee meeting
Brian Ernewein
Finance committee I can make an attempt at the question. The short answer is to confirm the premise of your question, which is that we don't connect at the hip, if you will, the trade agreements and tax treaties. There's a separate analysis that goes on. There's sort of a government-level decisi
February 5th, 2013Committee meeting
Brian Ernewein
Finance committee Just to recap the stats, without taking time to list individual country names, we have 90 treaties in force, all of which have an exchange of information provision, and almost all of which are at the current OECD standard and practice. We have 16 more TIEAs in place. We have list
February 5th, 2013Committee meeting
Brian Ernewein
Finance committee Yes, that's right. Assuming we have all the ones under negotiation signed, sealed, and delivered, so to speak, we wouldn't down tools. I think we'd be looking at others as well. There hasn't been a prioritization exercise set in that respect, but I think we'd take that on. The o
February 5th, 2013Committee meeting
Brian Ernewein
Finance committee I was going to say zero, but that's not quite right. There was I think an exchange of information agreement with Mexico that existed for some time before a tax treaty with Mexico was signed to replace it. The short answer is effectively zero, because the tax information exchang
February 5th, 2013Committee meeting
Brian Ernewein
Finance committee In fairness, let me first of all say that exchange of information has been a component of our tax treaty since before 2006. To be clear, it's the separate identification of TIEAs with non-treaty countries, sometimes termed as tax havens, that is the new element. In relation to
February 5th, 2013Committee meeting
Brian Ernewein