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Protocol amending the Canada-US Tax Treaty enters into force

Norton Rose Canada LLP
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Canada, USA
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January 22 2009

Last month the Canadian Minister of Finance and the US Treasury Secretary announced the entry into force of the Fifth Protocol to the Canada-United States Income Tax Convention, 1980 (the “Treaty”), which updates and amends the Treaty

Planning for the entry into force of treaty changes affecting hybrid entities on January 1, 2010

McCarthy Tétrault LLP
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Canada, USA
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September 30 2009

The Fifth Protocol to the Canada-US Tax Convention, 1980 (Canada-US Treaty) introduced important changes of interest to US multinational enterprises with hybrid entities, such as unlimited liability companies (ULCs) and limited liability companies (LLCs), in their cross-border structures

Important note to US investors into Canada using hybrid entities

Gowling Lafleur Henderson LLP
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Canada, USA
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May 28 2009

Canadian unlimited liability companies ("ULCs") have been used for some time now by US-resident investors into Canada for a variety of reasons, including to finance Canadian activities

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

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

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

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

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”

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

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Search results

Protocol amending the Canada-US Tax Treaty enters into force

Planning for the entry into force of treaty changes affecting hybrid entities on January 1, 2010

Important note to US investors into Canada using hybrid entities

Non-resident withholding tax on interest on the way out

Canada-US tax treaty changes

Canada-U.S. Protocol moves toward ratification

Canadian withholding tax eliminated on interest payments to unrelated US lenders

US final regulations on deferred compensation no longer deferred

Highlights of the new protocol to the CanadaUS Tax Treaty

Update on Canada-US tax treaty

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