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Canada - U.S. Tax Treaty: A Practical Interpretation

Canada - U.S. Tax Treaty: A Practical Interpretation

  • Publisher: CCH Canada
  • ISBN: 9781554960026
  • Published In: January 2009
  • Format: Paperback
  • Jurisdiction: Canada ? Disclaimer:
    Countri(es) stated herein are used as reference only
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    The Fifth Protocol to the Canada - U.S. Income Tax Treaty has introduced a myriad of changes relating to the rights of both countries to tax income earned by their respective residents. Canada - U.S. Tax Treaty: A Practical Interpretation is an invaluable resource designed to assist practitioners with clients involved in cross-border business activities deal with the complexity and uncertainty of these changes.
      
    CCH Canadian’s Canada - U.S. Tax Treaty: A Practical Interpretation contains the full text of the Canada - U.S. Tax Convention, as amended by the First through Fifth Protocols, with commentary by Dentons following each Article of the Treaty. The commentary provides a detailed analysis of the Fifth Protocol, including:
    • Changes to the “tie-breaker” rule for determining the residence of a corporation that qualifies as a resident of both Contracting States
    • Entitlement to Treaty benefits for “fiscally transparent entities”
    • New permanent establishment rules
    • Elimination of withholding tax on certain interest payments
    • Taxation of a non-resident’s emigrant gains
    • Taxation of “income from employment” earned by non-residents
    • Taxation of stock options received by individuals employed in both Canada and the United States
    • Introduction of a reciprocal limitation of benefits provision
    The Technical Explanations of the Treaty and the Third, Fourth, and Fifth Protocols, as provided by the U.S. Treasury Department, are reproduced, along with a report on the Fifth Protocol by the Joint Committee on Taxation for the U.S. Senate. Other useful resources contained in this edition include:
    • Annotations of related Dominion Tax Cases
    • Memorandum of Understanding between the Competent Authorities of Canada and the United States Regarding the Mutual Agreement Procedure
    • Agreement between the Government of Canada and the Government of the United States of America with Respect to Social Security
    • Income Tax Conventions Interpretation Act
    • Rates of Withholding Tax under Income Tax Agreements Signed by Canada

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