Section 273

FATCA influence on Part XIX common reporting standard (p. 6)

The OECD model CRS is heavily influenced by FATCA and the associated Model 1 Intergovernmental Agreement on which the Canada-US Intergovernmental Agreement (Canada-US IGA) is based. Thus, many concepts in the part XIX proposal are similar to those in part XVIII, which implement the Canada-US IGA. Similarities include the types of passive entities that will be looked through to controlling persons, and an exemption for registered accounts such as RRSPs and TFSAs.

Comparison with FATCA (p. 7)

Part XIX and the OECD model CRS are similar to the Camada-US IGA in part XVIII and in FATCA, but there are important 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.