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