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Results:1-10 of 23

STEP Canada CRA Roundtable, June 13, 2017
  • Gowling WLG
  • USA, Canada
  • June 15 2017

Following the presentation at the 2017 STEP Canada National Conference, we are pleased to provide you with a summary of the questions discussed at


Article XV(2) of the Canada-U.S. Treaty problems impacting Canadian employees working in the U.S.
  • Gowling WLG
  • USA, Canada
  • 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.


Canada Revenue Agency's interpretation of: "permanent establishment"
  • Gowling WLG
  • USA, Canada
  • September 20 2010

Under the Canada-U.S. Income Tax Convention (the “Treaty”), a corporation resident in the United States may be taxed in Canada where its activities give rise to a “permanent establishment”.


Pleading the 5th: U.S. Department of Treasury disappoints on cross-border hybrids
  • Gowling WLG
  • USA, Canada
  • September 12 2008

By way of background, the “Fifth Protocol” is a protocol to amend the Canada-U.S. Tax Convention


Technical Explanation to Canada-US Protocol released
  • Gowling WLG
  • USA, Canada
  • July 17 2008

On July 10, 2008, the U.S. Department of the Treasury released its long awaited Technical Explanation of the Fifth Protocol (the "Protocol"), which protocol will amend the Canada-U.S. Tax Convention (the "Convention").


Moving to the United States: tax consequences and planning opportunities
  • Gowling WLG
  • USA, Canada
  • June 15 2008

Moving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move.


New protocol to revise Canada-U.S. Tax Treaty
  • Gowling WLG
  • USA, Canada
  • May 15 2008

A new Protocol to the Canada-U.S. Tax Treaty was recently signed and is expected to enter into force in the near future, causing substantial changes to the taxation of cross-border transactions with the U.S.


Impact of the new tax protocol on limited liability companies, unlimited liability companies and debt financing: opportunities and challenges in cross-border transactions
  • Gowling WLG
  • USA, Canada
  • October 10 2007

The Fifth Protocol to the Canada - U.S. Tax Convention, dated September 21, 2007 (the "Protocol") will have a significant impact on cross-border transactions given the proposed treatment for hybrids and the elimination of withholding tax on interest on arm's length cross-border debt.


Highlights of the new protocol to the CanadaUS Tax Treaty
  • Gowling WLG
  • USA, Canada
  • 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").


Josh Rosen
  • Gowling WLG