The Fifth Protocol to the Canada United States Income Tax Convention - Highlights
-
Reducing
source country "withholding" tax to zero on cross-border
interest payments;
-
Allowing
taxpayers to require that otherwise difficult double tax issues be
settled via arbitration;
-
Making
sure that there is no double taxation of emigrants gains;
-
Extending
treaty benefits to flow through entities such as limited liability
companies in Canada;
-
Giving
mutual tax recognition of pension contributions such as RRSP and IRA
401(k) contributions;
-
Clarifying
how stock options are taxed; and
-
Implemented
various technical improvements and updates
The Canada-United States income tax convention
was signed in 1980. This
is the fifth set of changes and hence "Fifth Protocol."
