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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  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  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

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  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  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