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Article XV(2) of the Canada-U.S. Treaty problems impacting Canadian employees working in the U.S.

• Gowling Lafleur Henderson LLP
• -
• Canada, USA
• -
• May 4 2011

The 5th Protocol to the Canada-United States Tax Convention (1980) (the “Treaty”), which entered into force on December 15, 2008, introduced several significant and highly anticipated changes to the Treaty. There were also several minor amendments made to the Treaty, including one to Article XV that was intended only to be clarifying in nature