Fifth protocol: proposed amendments to United States-Canada Income Tax Treaty.
Tax Executive › Vol. 60 Nbr. 1, January 2008
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Fifth protocol: proposed amendments to United States-Canada Income Tax Treaty.
Almost twenty-seven years to the day after the Convention between the United States of America and Canada with respect to Taxes on Income and on Capital (Treaty) was signed (September 26, 1980), officials in the two countries executed (September 21, 2007) the Fifth Protocol to this Treaty (2007 Protocol). (1) The 2007 Protocol will enter into force on the date that Canada (2) is notified of the U.S. Senate's ratification of the 2007 Protocol. (3) Optimally, this will happen in 2008.
The negotiations for the 2007 Protocol lasted for more than a decade and began with a provision found in the 1995 protocol, mandating negotiations regarding the interest withholding tax within three years of the signing of the earlier protocol. (4) Most commentators view the 2007 Protocol as beneficial for both countries, but there are some who believe that the detriment to U.S. businesses, especially those in the service industry, outweigh the benefits provided by the 2007 Protocol. (5) This article addresses the Protocol's significant amendments to the Treaty. (6) Reduction of Withholding Tax on Interest to Zero First and foremost, ...See the full content of this document
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