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Current CRA website
Guidance on the Common Reporting Standard
Account held by an intermediary other than a financial institution 5.9 When a financial account is held by an intermediary other than a financial institution (for example, a law firm) that is not described in paragraph 5.17, but is an account holding, on a pooled basis, the funds of underlying clients of the intermediary where: the only person listed or identified on the financial account with the financial institution is the intermediary; and the disclosure or passing by the intermediary of its underlying clients' information to the financial institution contravenes Canadian law, the financial institution is required to undertake the due diligence procedures only in respect of the intermediary. ...
Current CRA website
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement
Notice of the competent authority agreement. 5.8 When a financial account is held by an intermediary other than a financial institution (for example, a law firm) that is not described in paragraph 5.6 but is an account holding, on a pooled basis, the funds of underlying clients of the intermediary where: the only person listed or identified on the financial account with the financial institution is the intermediary; and the disclosure or passing by the intermediary of its underlying clients’ information to the financial institution contravenes Canadian law, the financial institution is required to undertake the due diligence procedures only in respect of the intermediary. ...