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.

Summary Under
Tax Topics - Treaties - Canada-US Enhanced Tax Information Agreement Implementation Act [FATCA IGA] - Article 4 - Section 2
Potential requirement to withhold re a recalcitrant account holder (p. 485)

...FATCA generally requires an FFI to withhold 30% on payments from...

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Summary Under
Tax Topics - Income Tax Act - Section 264 - Paragraph 264(1)(c)
Opening of 2nd account by holder of pre-existing account (p. 486)

The use of the Treasury Regulation definition of "preexisting obligation" is not...

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