As MPs tell their constituents what a good deal Canada’s IGA signing with the USA is, I am posting this so others can consider.
I will have to read this a few more dozen times to get my head around it.
Roy Berg’s conclusion is:
“I can’t go back to yesterday because I was a different person then.”
Lewis Carroll, Alice in Wonderland
Non-US trusts occupy an unenviable position in FATCA-Land. Most will be classified as Financial Institutions and therefore will have to carefully navigate the vagaries of domestic and international law in order to avoid the consequences of inadvertent non-compliance. The Canada-United States IGA goes a long way to mitigate the compliance cost and consequences of non-compliance but, as noted, some clarifications are required.
Just as Alice couldn’t go back to the person she once was, neither can we go back. FATCA has changed the global banking, business and tax landscape – and more changes will follow.