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

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 la

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  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  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

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  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 tha

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

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  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. Whethe

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. indica

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.

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.