Roy Berg (of “jingoistic hyperbolic rhetoric” fame) has written an article for Tax Analysts on the Summary Trial.
Stephen received permission to post the article at ADCS website. We cannot post the article here for copyright reasons, but you can read John’s Report on Roy Berg’s report at ADCS. There is a link there to Mr. Berg’s article.
The question is simple:
Do the provisions of the Canada U.S. FATCA IGA provide the conditions that would allow for the transfer of information that the FATCA IGA contemplates?
The answer is difficult
The plaintiffs say NO and the Government says YES.
We are all hoping the judge agrees with the plaintiffs.