CRS draft legislation contains some departures from FATCA

The OECD model common reporting standard (which is reflected in the Canadian draft legislation released on April 15, 2016 to add Part XIX of the ITA) is heavily influenced by FATCA and the associated Model 1 Intergovernmental Agreement on which the Canada-US Intergovernmental Agreement (Canada-US IGA) is based. However, there are some differences:

First, the CRS applies to reportable persons on the basis of their residence for tax purposes, with no reference to individuals with foreign citizenship, as with FATCA. Second, the Canada-US IGA provided for a de minimis exemption from a review of pre-existing accounts whose balance or value was less than US$50,000. Proposed part XIX does not include such a de minimis exemption for an account held by an individual, but instead provides that varying levels of review apply depending upon the account value.

Neal Armstrong. Summary of Kyle B. Lamothe, "Common Reporting Standard: Draft Legislation", Canadian Tax Highlights, Vol. 24, No. 5, May 2016, p. 6 under s. 273(3).