Technical explanation clarifies protocol to Canada-U.S. tax treaty

Resource Information

The work Technical explanation clarifies protocol to Canada-U.S. tax treaty represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Technical explanation clarifies protocol to Canada-U.S. tax treaty

Creator

• Marley, P.W
• Heale, A
• Morier, D

Subject

• services
• withholding tax
• hybrid entity
• LoB
• tax treaty
• PE

Language

eng

Summary

This article summarizes many of the changes to the Canada-U.S. treaty resulting from the Protocol and the main clarifications provided in the Technical Explanation. Many of these changes, such as elimination of withholding tax on most cross-border interest payments, are beneficial; others, such as the treaty benefit denial rules respecting hybrid entities, will significantly affect cross-border structures

Citation source

In: Journal of international taxation. - New York. - Vol. 19 (2008),

Geographic coverage

North America

Language note

English