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Article: Fifth protocol: proposed amendments to United States-Canada Income Tax Treaty.
- Article from:
- Tax Executive
- Article date:
- January 1, 2008
- Author:
CopyrightCOPYRIGHT 2008 Tax Executives Institute, Inc. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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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 ...