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US holds hearings on Fifth Protocol

Borden Ladner Gervais LLP
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Canada, USA
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July 18 2008

July 10, 2008 signalled the release of the Technical Explanation of the Fifth Protocol to the Canada-US Income Tax Convention, 1980 (the Convention), concurrent with the hearing on that date of the US Senate Committee on Foreign Relations on pending income tax treaties with Canada, Iceland and Bulgaria

Canada-US tax treaty changes

Stikeman Elliott LLP
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Canada, USA
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February 12 2008

On December 14, 2007, the fifth Protocol to the Canada-U.S. Income Tax Convention (the "Treaty") was ratified by Canada when Bill S-2 received royal assent

US final regulations on deferred compensation no longer deferred

Osler, Hoskin & Harcourt LLP
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Canada, USA
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May 9 2007

The long-awaited regulations under Section 409A of the US Internal Revenue Code relating to deferred compensation were finally issued on April 10, 2007 and are applicable for taxable years beginning on or after January 1, 2008 (the “Final Regulations”

Canadian withholding tax eliminated on interest payments to unrelated US lenders

Torys LLP
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Canada, USA
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February 19 2008

As of January 1, 2008, withholding tax is no longer payable on most interest payments made by Canadian borrowers to arm’s-length lenders, including lenders that reside in the United States

Canada-U.S. Protocol moves toward ratification

Gowling Lafleur Henderson LLP
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Canada, USA
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August 8 2008

On July 29, 2008 the Fifth Protocol (the "Protocol") to the Canada-U.S. Tax Convention (the "Convention") was ordered to be reported "favorably" and "without amendment" out of the U.S. Senate Foreign Relations Committee

Non-resident withholding tax on interest on the way out

McMillan LLP
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Canada, USA
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July 17 2007

One of the issues which has long been a source of frustration for both borrowers and lenders in cross-border loan transactions relates to the imposition of withholding tax on non-resident interest payments

New Protocol to Canada-US Tax Treaty elimination of withholding tax on interest and other changes

McMillan LLP
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Canada, USA
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September 21 2007

Canada and the United States signed the widely anticipated 5th protocol (the “Protocol”) to the Canada-U.S. Tax Treaty (the “Treaty”) today

Highlights of the new protocol to the CanadaUS Tax Treaty

Gowling Lafleur Henderson LLP
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Canada, USA
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September 25 2007

On Friday, September 21, 2007 Canada's Minister of Finance and the US Secretary of the Treasury signed a protocol (the "New Protocol") updating the Canada-US Tax Treaty (the "Treaty"

Update on Canada-US tax treaty

Norton Rose Canada LLP
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Canada, USA
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September 24 2007

The March 19, 2007 Federal Budget announced that an agreement in principle had been reached to amend the Canada-United States Income Tax Convention, 1980

Update on Canada-US Tax Treaty - hybrid entities

Norton Rose Canada LLP
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Canada, USA
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September 27 2007

On September 21, 2007, the Minister of Finance announced the signing of the Fifth Protocol to the Canada-United States Income Tax Convention, 1980 (the “Treaty”), which updates and amends certain provisions of the Treaty

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Search results

US holds hearings on Fifth Protocol

Canada-US tax treaty changes

US final regulations on deferred compensation no longer deferred

Canadian withholding tax eliminated on interest payments to unrelated US lenders

Canada-U.S. Protocol moves toward ratification

Non-resident withholding tax on interest on the way out

New Protocol to Canada-US Tax Treaty elimination of withholding tax on interest and other changes

Highlights of the new protocol to the CanadaUS Tax Treaty

Update on Canada-US tax treaty

Update on Canada-US Tax Treaty - hybrid entities

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