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Overview of limitation on benefits article in Canada-U.S. Tax Treaty

  • Miller Thomson LLP
  • -
  • 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"