Canada-U.S. Tax Treaty: A Practical Interpretation

1942 Convention allowed amended annuity apply arbitration board arising Article XI Article XXIX beneficial owner Canadian resident Canadian tax capital Code section competent authority Contracting deduction deemed derived determination dividends double taxation drilling rig enters into force entity example exchange Fifth Protocol first-mentioned fiscally transparent fixed base foreign tax credit Fraser Milner Casgrain gains graph Income Tax Act individual Internal Revenue Code item of income limited OECD paragraph 9 payments pension period permanent establishment proposed protocol Protocol enters provides provisions of Article provisions of paragraph pursuant qualifying person real property resident of Canada respect Roth IRA RRSP rules September 26 social security subparagraph Tax Act Canada tax law tax treaty taxable income taxes imposed taxpayer Technical Explanation term Third Protocol tion trade or business treaty country trust U.S. citizen U.S. estate tax U.S. resident U.S. tax purposes U.S.-source unified credit United USCo VII Business Profits withholding tax