Finance committee  Is that 800 million U.S. citizens residing in Canada?

Finance committee  I don't have that figure, I'm sorry.

Finance committee  But only 6% owe any U.S. tax.

Finance committee  The IGA, in fact, has its own set of rules. But as I said before, your treasury is aware that model 1 IGAs require domestic law to implement. So there is the potential for some deviation from existing definitions.

Finance committee  And so the U.K. mirrored the definitions found in the regs.

Finance committee  Right now that's the biggest issue that we have with the draft legislation. Under the draft legislation, private trusts, private holding companies, are not Canadian financial institutions. They're not FIs. And for those type of entities that have purely Canadian affairs, that's g

Finance committee  It changes every day.

Finance committee  Yes, exactly. Who's right? We know that you're just doing the legal analysis. We've come up with a different answer than the Department of Finance has. It doesn't mean that the Department of Finance is wrong, but if we look to other jurisdictions such as the U.K. and how they've

Finance committee  Good afternoon, Mr. Chairman and members of the committee. My name is Roy Berg. I'm a U.S. tax lawyer with Moodys Gartner. I was born, raised, and educated in the U.S. I practised in the U.S. for 17 years in tax law before immigrating to Canada three years ago. Therefore, I thin