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Overview of limitation on benefits article in Canada-U.S. Tax Treaty
- Miller Thomson LLP
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- Canada, USA
- -
- April 17 2013
The Canada-United States Tax Treaty (the "Tax Treaty") is unique among Canada's tax treaties in its approach to prevent "treaty shopping". Treaty
Cross-border tax: Canada-US Tax Treaty update CRA views on treaty entitlement on Canadian source income and profit for US LLC shareholders
- Miller Thomson LLP
- -
- Canada, USA
- -
- October 5 2010
The Canada Revenue Agency ("CRA") recently confirmed that it continues to maintain its long-standing position that a US limited liability company ("US LLC") that is treated as a fiscally transparent entity for US tax purposes is not entitled to treaty benefits under the Canada-US Tax Treaty, as amended by the Fifth Protocol ("Treaty"
