tax system (such as foreign tax credits) that do not affect how the item of income is treated under U.S. law in the first instance. This article reviews therecent public statements mentioning the DCL rules in conjunction with Article IV(7)(b) and GAAR and con- siders their broader ...
International Tax JournalNitikman, J. (Winter 2000). ``The Interaction of Cana- da's Thin Capitalization Rule and the Canada- United States Tax Treaty.'' The International Tax Jour- nal 26(1), 20-64.Greenvale.The Interaction of Canada’s Thin Capitalization Rule and the Canada--United ...
协定高林treaty事务所律师tax 加拿大与香港签署新的税务协定 作者:**·威尔逊和许嘉富 简介: 2012年11月11日,在经过不长时间的谈判之后,加拿大政府和中国香港特别行政区政 府正式签署了税务协定(简称“协定”)。早在1986年,加政府已与中国政府签订了类 似的税务协定(简称“加中协定”),因此,考虑到很多香港居民与...
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsoredMultilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting(the MLI). As noted in our prior blog (New Ratifications of the OECD's Multilateral Instr...
tax treaties between the two countries, such as the Canada-US Tax Treaty, is vital as it determines how various types of income are taxed, including employment income, investment income, and retirement income. Working with a cross-border financial advisor specializing in...
Fifth protocol to the Canada-US income tax convention signed. The article reports that on September 21, 2007, Canada and the U.S. signed a new protocol to the Canada-U.S. tax convention, or the treaty. One of the most... Maclagan,Bill,Zimka,... - 《International Tax Review》 被引...
For over seventy years, damages for lost earnings and for pain and suffering were ... SB Cohen,Laura Sager - 《Harvard Journal on Legislation》 被引量: 1发表: 2006年 The New US - Netherlands Tax Treaty Protocol. This article focuses on the new U.S.-Netherlands tax treaty protocol. The...
Cyprus Signs Double Tax Treaty Agreement with Iran, for the Avoidance of Double Taxation on Income and Capital To restate, it is extremely important that the new US-Ireland treaty continues to allow Irish ETFs to access US treaty benefits. The optimal way to achieve... C Savva 被引量: 0发...
tax treaty and the limitation on benefits provision: a justifiable compromise? On November 9, 1995, Canada and the United States ratified the Third Protocol tothe Canada-US. Income Tax Convention. The Protocol will benefit Canadians engagedin cross-border business as it eliminates many pre-...
can help you navigate through the complexities of the US Canada Income Tax treaty. This includes consulting on permanent establishments, taxability of business profits, treaty based tax return filings, as well as consulting regarding the applicability of reduced rates of withholding under this treaty....