Canada U.S.

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

CCH Canada January 2009

Specifications

ISBN-13
9781554960026
Publisher
CCH Canada
Publication
January 2009
Format
Paperback
Jurisdiction
Canada ? Countri(es) for reference only

Details

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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