And there is appears to be some activity with the US. As shown at the links below Brian Ernewein who is the General Director of the Tax Policy Branch at Finance Canada traveled to the US twice over the summer once in June and once in August.
The first meeting was with generic US Government officials(which I take to include both Treasury and IRS and possibly FINCEN) and the second was with US Treasury Staff. About a week after Ernewein’s June meeting the new expat super minnow program was announced. I don’t know whether or nor this was a coincidence. Ernewein also June went to a big OECD conference in Paris as did one of the Assistant Commissioner’s at CRA. I will try to find a picture or video of Ernewein so you can put a picture to the name. I will note while he is high up he is not at the level of Deputy Minister or Assistant Deputy Minister which are filled by Michael Horgan and Louise Levonian respectively. Links below:
http://www.fin.gc.ca/comment/adm-2-eng.asp
http://www.fin.gc.ca/comment/dm-eng.asp
My personal opinion is truly serious negotiations need to involve either Levonian or Michael Horgan. By definition Brian Ernewein I doubt met anyone higher than Manal Corwin, Emily McMahon, Michael Plowgian etc.
There is chatter about various meetings as below. In them, it appears to be strictly about implementation details and zero discussion about the misery being implemented.
It ought to be considered if the ACA reps could attend the OECD meetings from their European base and the international law meetings from their Wash office.
Where are the forums where human issues are discussed?
a meeting of joint international committees at the American Bar Association, Sept 12, 2012. Presenters:
Acting Treasury International Tax Counsel Danielle Rolfes
IRS Associate Chief Counsel (International) Steven Musher
It was noted:
–their agencies had been working to cut the known FFI rulebook from its 400 pages
–during a reporter session, apparently in response to the plees for more time for the FFI’s to implement while the regs are still in draft, Danielle Rolfes said it’s possible the FFI agreement might have to be “immediately effective”
Their next meeting is from 1:00 to 2:00 p.m. on Thursday, October 11, 2012, at the La Quinta Resort and Club in La Quinta, California.
http://apps.americanbar.org/dch/committee.cfm?com=IL216000
Also, an OECD meeting, with the agenda below, where
–the US treasury team stated that the final FFI regs would be released by Halloween,
–reps expected the timelines for implementing FFIs in IGA and non-IGA countries to be aligned, so there would be no time gap in the schedules between them
The briefing session will provide business with an opportunity to hear from the architects of the model about its background, operation and latest developments. The model will be presented by Ms. Manal Corwin (Assistant Secretary for International Tax Affairs, US Department of Treasury) and Mr. Michael Plowgian (Attorney-Advisor, Office of the International Tax Counsel, US Department of Treasury). Participants will also be given an opportunity to ask questions to government representatives from countries involved in the development of the model.
http://www.biac.org/members/tax/docs/2012_08_21_Invitation_OECD_BIAC_briefing_session_on_FATCA_Model_IGA.pdf
@ Mark and Tim
Although there has been much chatter in international financial and legal circles, I’ve come to perhaps the same conclusion that I think Tim has, i.e., FATCA implementation will be delayed.
Even with a Halloween release of new regulations (how appropriate), it’s still way too late for FFIs and governments to react by January 1, 2013.
Regarding the Canadian position, the “deafening silence” could just be because nothing is happening of any significance.
For now, we can only speculate. Time will tell.
When the implementation is set, then I will know my timetable to send my assets and my ass to China or Cuba, where I can be safe from persecution.