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Finance committee I think I can say without any hesitation that it certainly would have been more. This is an obligation on the banks. I've made the point more recently, in another discussion, that I'm sure the banks aren't tickled by this, even with what we have done. I do think they have taken t
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Thank you. This is purely an information agreement, so it's about collecting information from financial institutions and providing that information through the Canada Revenue Agency to the IRS. As to what systems and collection provisions we have with the United States, there i
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee If they are not a Canadian citizen.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee It's a very good but very involved question. At a high level I will say this. We already require entities and other taxpayers who are making payments to non-residents to identify those payments and to provide that information to Revenue Canada. When the payment is going to a re
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee It does, so we'll be collecting some additional information from the U.S., particularly in relation to what I've talked about as taxpayer identification numbers. I do want to say though, for completeness, that it's not at the same level at the outset. The U.S. has asked the cou
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee We are not talking about individuals alone. We've often, because that's where the conversation has led, talked about U.S. residents and citizens, but there's some relevance to entities as well. If you'd like, we could give you some more information on the entities.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Well, I'll answer that question first, and then if you're still interested we can talk about how the rules work in relation to entities. It's the same restrictions on the use of taxpayer information that I talked about earlier that would apply there. There is a question of relian
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee That's right. There's a question of—as I say—the reliability of our treaty partner. We do take the view that we can rely on the U.S. to limit it's use of the tax information as, indeed, they rely on us.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Yes. That would be inconsistent with their commitments to us and their legislation, so it would only be on the basis that they were violating the agreement that it could happen.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Well, the answer is no, because we challenge the premise of the question—
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee We exchange information already with the U.S. and with other treaty partners, on which we rely on the terms of the agreement we have with them.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Forgive me, I'm not sure if I understand how they're affected in the way you suggest.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee I don't know of any. To take the specific example you raise, if there's a person who's living in Canada while a green card holder...so they're actually living in the U.S.?
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee All right. Well, in those circumstances they'd be exposed, if you want to call it that, to the U.S. tax system already. Their income would be subject to U.S. tax by virtue of the U.S. employment.
May 1st, 2014Committee meeting
Brian Ernewein
Finance committee Not that it occurs to me.
May 1st, 2014Committee meeting
Brian Ernewein