Today, the Federal Court of Canada rejected a challenge to Canada’s implementation of the intergovernmental agreement (IGA) between the United States and Canada.  According to the decision, “collection and automatic disclosure of account holder information about US reportable accounts…contemplated by Articles 2 and 3 of the IGA is legally authorized in Canada.”  Other issues raised in the litigation have not yet been decided by the court, including whether the IGA and related implementing legislation violate Canadian citizens’ constitutional rights.  The court stated, “[t]he declaratory and injunctive relief requested by the plaintiffs in their motion for summary judgment is denied, without prejudice to the plaintiffs’ right to pursue their claim that the impugned provisions are ultra vires or inoperative because they are unconstitutional or otherwise unjustifiably infringe Charter rights.”