The inter-governmental agreement (IGA) between the USA and Canada which will enforce FATCA in Canada has an interesting line on page 27:
With respect to New Individual Accounts not described in paragraph A of this section, upon account opening (or within 90 days after the end of the calendar year in which the account ceases to be described in paragraph A of this section), the Reporting Canadian Financial Institution must obtain a self-certification, which may be part of the account opening documentation, that allows the Reporting Canadian Financial Institution to determine whether the Account Holder is resident in the United States for tax purposes (for this purpose, a U.S. citizen is considered to be resident in the United States for tax purposes, even if the Account Holder is also a tax resident of another jurisdiction) and confirm the reasonableness of such self-certification based on the information obtained by the Reporting Canadian Financial Institution in connection with the opening of the account, including any documentation collected pursuant to AML/KYC Procedures.
We have to understand that US tax code treats US persons (i.e., US citizens and permanent residents) who live abroad as resident in Washington DC. The IGA appears to acknowledge this fiction, saying that for tax purposes a US citizen is resident in the USA, their Canadian residence and citizenship notwithstanding. The Tory government has now accepted the US fiction that US citizens abroad are not entitled to representation because they are resident in Washington DC. This amounts to financially kidnapping Canadian citizens and turning them over to a foreign government. Such an action by the Harper government is treason. Please contradict me if I am wrong.