Canada - U.S. Tax Treaty: A Practical Interpretation, 4th Edition
Canada-U.S. Tax Treaty: A Practical Interpretation with expert commentary by Dentons on all Article of the Treaty.
This update also includes a discussion of the new U.S. FATCA legislation and related Canadian domestic law requiring certain Canadian financial institutions and other "U.S. persons" to provide the IRS with account information of U.S. taxpayers residing in Canada. This will help practitioners in advising clients who may now have new U.S. filing obligations and to help mitigate the tax risk to their investment portfolio.
Wolters Kluwer's Canada-U.S. Tax Treaty: A Practical Interpretation contains the full text of the Canada - U.S. Tax Convention, as amended by the First through Fifth Protocols, with updated commentary by Dentons following each Article of the Treaty. The Technical Explanations of the Treaty and the Third, Fourth, and Fifth Protocols, as provided by the U.S. Treasury Department, are reproduced, along with a report on the Fifth Protocol by the Joint Committee on Taxation for the U.S. Senate. Other useful resources contained in this edition include:
- Annotations of related Dominion Tax Cases
- Memorandum of Understanding between the Competent Authorities of
Canada and the United States Regarding the Mutual Agreement Procedure
- Canada-U.S. Social Security Agreement
- Income Tax Conventions Interpretation Act
- Rates of Withholding Tax under Income Tax Agreements Signed by Canada
- Canada-U.S. Enhanced Tax Information Exchange Agreement
Dentons is the world's first polycentric global law firm. A top 20 firm on the Acritas 2015 Global Elite Brand Index, the Firm is committed to challenging the status quo in delivering consistent and uncompromising quality and value in new and inventive ways. Driven to provide clients a competitive edge, and connected to the communities where its clients want to do business, Dentons knows that understanding local cultures is crucial to successfully completing a deal, resolving a dispute or solving a business challenge. Now the world's largest law firm, Dentons' global team builds agile, tailored solutions to meet the local, national and global needs of private and public clients of any size in more than 125 locations serving 50-plus countries. www.dentons.com.
Jesse S. Brodlieb
Larry is a Chartered Accountant, having received his CPA, CA designation from the Institute of Chartered Accountants of Ontario, and he is a member of the Chartered Professional Accountants of Canada.
As a partner with Dentons Canada LLP, Tony specializes in international tax. He advises corporations and individuals on cross-border tax structures, withholding taxes as well as transfer pricing issues. He also advises on Canadian corporate tax issues affecting private corporations as well as on deferred compensation arrangements. He advises pension funds on structuring and financing their domestic and international real estate and other investments and is the head of Dentons' Pension Fund Corporations practice group.