Law Note - Protocol to the Canada-U.S. Tax Treaty 


Winter 2008 - (InBrief Winter 2007/2008)

InBrief Winter 2007/2008

On September 21, 2007, Canada and the United States signed a Protocol agreeing to significant amendments to the Canada-U.S. Tax Treaty. The Protocol will come into force once ratified by both governments. If ratified in 2007, it will come into force generally as of January 1, 2008.

While key elements of the proposed amendments have been broadcast for some time (elimination of cross-border withholding tax on interest and extension of treaty benefits to U.S. LLCs, for example), the Protocol will implement additional, far-reaching changes in the context of cross-border structures.

Ed.: These paragraphs introduce a detailed article issued as a Tax Law Alert on October 3, 2007. The writers may be contacted for more information on these topics or for advice relating to specific circumstances or structures.

This law note appeared in InBrief Winter 2007/2008.