Finance committee  I think that is very reasonable. If I were in that position, which I am, I would want that passed along. But I think the place for that is in the domestic legislation, not in the IGA itself.

Finance committee  I'm sorry, it should be in Canadian domestic legislation.

Finance committee  I don't believe they do.

Finance committee  Probably not, but it could become a magnet for tax cheaters and avoiders.

Finance committee  Yes, that's correct.

Finance committee  That is correct.

Finance committee  If some banks don't comply, then under FATCA, they would be non-participating financial institutions, and there would be a 30% withholding tax on them. And that's a withholding tax and not a withholding-against tax. It is a tax. You don't get it back. Under the IGA, Canadian fin

Finance committee  It is in the Canadian banks' best interest to be a participating financial institution, that's correct.

Finance committee  First of all, the seminal question is, are you a financial institution or not? If you're a financial institution under Canadian law, then you're obligated to do certain things. Those certain things include figuring out who your U.S. citizen depositors are.

Finance committee  That is under the IGA and also under the treasury regulations.

Finance committee  You find out, yes, whether you had indicia of U.S. citizenship or U.S. personhood, and once that decision has been made, then there is a reporting to CRA.

Finance committee  My understanding is that there is no obligation for notification under the legislation. I don't believe there was any notification requirement under the Canadian guidance notes. There is no notification obligation either in the IGA or under the Treasury rules.

Finance committee  That's a very good point, and thank you for your question. Several jurisdictions have asked the U.S. to enter into memoranda of understanding where there are questions as to interpretation of the IGA. The reason that you would enter into the memorandum of understanding is precis

Finance committee  It seems that they are doing that.

Finance committee  It is an information grab, I would say. When we look at the actual tax dollars collected from U.S. citizens residing abroad, the IRS came out with statistics two years ago that said only 6% of any returns filed from abroad ever owe any U.S. tax. This is not a big tax grab; it's