Canadian financial institutions are permitted under the FATCA rules to open up accounts for recalcitrant account holders

Findings of Candice Turner on the application of the FATCA rules to Canadian financial institutions include:

• The institution likely can open up an account for a recalcitrant account holder who fails to provide a U.S. tax information number (although withholding tax would be imposed on U.S.-source withholdable payments).
• When a holder of a pre-existing individual account opens a new account with the same financial institution, there is no need to re-document the account so long as the required due diligence has been (or is being) conducted and, where a threshold has been applied to the pre-existing account, the institution's computer is able to link the new account to the pre-existing one.
• Respecting the measurement of account threshold levels corresponding to different due diligence levels, the previous balances of closed accounts should be ignored.

Neal Armstrong.  Summaries of Candice M. Turner, "Answers to Practical FATCA Questions for Canadian Financial Institutions," Tax Management International Journal, Vol. 43, No. 8, August 8, 2014, p. 484 under FATCA IGA, Art. 4. s. 2, Annex 1, s. IV, para. A and Annex 1, s. VI, para. C.