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Change to Canada-US Tax Treaty affecting cross-border employees

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • December 19 2011

Article XV(2) of the Canada-US Tax Treaty (the “Tax Treaty”) provides for an exemption from taxation of remuneration derived by an employee resident in a country (referred to herein as “residence state”) in respect of temporary employment exercised in the other country (referred to herein as the “source state”