money go and when it was collected where does the money go when it's collected the money it depends upon which side of the equation you're looking with your client is only on one side of the equation so where did your clients money go our cl supposedly goes to canada on the other hand how is that raising revenue for the united states it raises revenue for the united states because it is the twenty six dollars can't be separated apart as to parts of their interview but if you flip the other side you've got the same issue if it's the united states judgment in a man is in canada we send it up there and they collected for the united states that that's true and that's one side of equation however if you have a if you read a man's house under that circumstance that tax under that circumstance is is assessed and imposed under the tax law which did originate in the house and but it in this case the tax that was on paid originated in collection effort on one side of it but on the other hand the other side collection the other side is its collection but it uses our assessments that you do so in the sole purpose if you really the technical if you really technical let me ask you something but that isn't raising revenue for the united states it's collecting a judgment for canada where the revenue raising aspect of this is that we are collecting through that interdependent stash of revenue that we would never receive because it's in canada and we couldn't otherwise get it except that revenue is assessed under our tax laws and you're not challenging our tax laws we're not challenging our hash out this this particular one m and where is supposed to accomplish the assessment statute itself is a revenue raising provision except the assessment statute was imposed was a not good in compliance with what you said it started my house is it is part of the iraqis but that assessment is not to collect the us tax it's not to build a collect revenue it is a maccan as some that the treaty incorporates to collect the committee well your honor that that may be true but the  problem here is that our assessments that you which was as you mention hasta originated in the house of representatives as it properly should set certain rules and that statute says so when you look at that yes you have the other originally originating properly in the house of representatives on the other hand you have this provision of this tre and it seems to me what's really happening is the united states government is not collecting a revenue for the united states it is a system can stop pursuant to an agreement with canada that last to help canada collect its taxes w assessed under canadian law this is correct but at the same time it's in her opinion because there's no reason to have one side of the equation which is there that that that our assistance of canada  collecting their taxes when they are having their part which is canada is allegedly raising our revenue which we've not yet and that is how we can accept our revenue our taxes are assessed the taxes that of the court of the nd state farm's it and allows it to be enforced if it were entered in that state that's all this is your honor if if this was we had if this provision was handled theirs which we can't collect and we have this interdependent agreement its own battery which is not to involve the house represent and they are going to collect  revenues which we could not otherwise tax code but it is revenue to the united states and canada just helps us caught that but the taxes imposed on the tax code and is a revenue for the united states and you're not arguing that the tax code is unconstitutional technical explanation says that the reason that and when you read the title explanation of the treasury department in this case they say that the reason they are entering into this statute is because  revenue service has claims against persons in canada that would be subject to collection oh these provisions not subject otherwise if you read the whole technical explanation that is the only reason th in getting into whether that is a bill for raising revenue we say that they've admitted that because it's a bill for raising revenue in that sense number twenty when you read the supreme court cases that  probable they dealt with in those cases which was a national program of significance that have a tax associated with that program to defray the cost of that program instead we have here  what we believe this is the supreme court's interpretation and that is that where you have the where the purpose of the legislation is the raising of revenue which we believe that is the purpose of the the the law because he flew in you if you look at this here is a case and they all use just the stories comment that his commentary about what he was talking about in the roberts case what the saying is that if you have a special program then if you have a tax that's incidentals in that it's attached that to defray those costs it does not revenue raising it's not revenue rise and we agree one hundred percent with that but if you read the rest of that case i mean the which is exactly what happens here the money that the united states gets back if you cancel it that's your theory that anything where the purpose is to raise revenue is covered by their origination caused does it follow that all the information sharing provisions and treaties like this one are also encountered because you can originate in the house no your honor well why not the purpose of those is also to raise revenue well the reason the reason is this those cases triggered when there's an information sharing provision in a treaty because if the purpose cause delays right now this is what the court said they sense it's nothing in the constitution grants karmas the exclusive power to authorize the exchange lawfully collect i just match bets what they're being or you're not answering my question my question is the purpose of information sharing provisions is to raise revenue if everything is subject to the original originat talking about assessment of taxes we're talking about taking taxes from somebody we're not already exchanging information than that but that's not the test you're asking us to adopt you want us to adopt a purpose test and my concern is that that would be very broad that when we authorize additional agents for the i r s the purpose is to collect more revenue that if we give the i r s a new building the purpose is to collect more revenue so i am wondering where the limiting principle is for your purpose based task well facilitate information exchange so we think this report got it got this case right that article twenty six a is constitutional and if there are no questions those what is it is it your position that they're not revenue raising program it is our position that they would that this is simply a matter of coordinating the two countries for the benefit of tax payers how and we would defend them as constitutional if they were to come out no i don't i understand they're not right but but so your position is they don't fall under the origination cause because they are not bills for raising revenue yes if it came of that would be our position your honor ok your position is that by having mutual collection with canada we actually increase our revenue because we're getting more revenue from ken that we otherwise would not have gotten without this mutual treaty and therefore the treaty itself is a revenue raising statute but the mechanism that the treaty uses is basically a collection of mapping as a which is attached to the tax laws of the respective states canada and in this case united states so the actual revenue raising is done through the tax laws of the respective countries and the mutual collection just in the hands of those tax laws and what we're saying measurable is that in if you get past the basic proclamation or statements that if it's of resident revenue raising so that you in the money goes to the treasury then it s because we now have canada as an additional agent that's helping us raise the revenue but the if you really look at that a little closer the bringing in canada into the help to port doing that isn't a bill raising revenue it's a bill collecting the tax the taxes imposed under the tassel and other words the revenue that the bill that says a person has to pay the tax is under our tax code and if he flees we don't get that tax so we have a collection problem so if we enter into this mutual agreements with countries we can collect those taxes that are imposed under our tax code and so that hour we have to take a step and that is to deem the canadian tax to be an assessment of taxes under our system and the assessment