Canada - U.S. Tax Treaty: A Practical Interpretation, 4th Edition

Since publication of the last edition of Canada-U.S. Tax Treaty: A Practical Interpretation when the Fifth Protocol of the treaty came into force, there have been significant changes to case law, technical interpretations and arbitration operating procedures. This edition has been updated with these changes to provide greater clarity to practitioners on the positions of the various courts and the CRA when applying for treaty benefits for their clients. Canada-U.S. Tax Treaty: A Practical Interpretation is an invaluable resource designed to assist practitioners who have clients involved in cross-border business activities in dealing with the complexity and uncertainty of these changes.

This update also includes a discussion of the new U.S. FATCA legislation and related Canadian domestic law requiring certain Canadian financial institutions and other "U.S. persons" to provide the IRS with account information of U.S. taxpayers residing in Canada. This will help practitioners in advising clients who may now have new U.S. filing obligations and to help mitigate the tax risk to their investment portfolio.

Wolters Kluwer's Canada-U.S. Tax Treaty: A Practical Interpretation contains the full text of the Canada - U.S. Tax Convention, as amended by the First through Fifth Protocols, with updated commentary by Dentons following each Article of the Treaty. The Technical Explanations of the Treaty and the Third, Fourth, and Fifth Protocols, as provided by the U.S. Treasury Department, are reproduced, along with a report on the Fifth Protocol by the Joint Committee on Taxation for the U.S. Senate. Other useful resources contained in this edition include:

• Annotations of related Dominion Tax Cases
• Memorandum of Understanding between the Competent Authorities of
  Canada and the United States Regarding the Mutual Agreement Procedure
• Canada-U.S. Social Security Agreement
• Income Tax Conventions Interpretation Act
• Rates of Withholding Tax under Income Tax Agreements Signed by Canada
• Canada-U.S. Enhanced Tax Information Exchange Agreement

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Jesse S. Brodlieb
Associate, Toronto

Jesse is an Associate in Dentons' Taxation Group. His practice includes advising clients on international and domestic income taxation matters, with a focus on corporate taxation. He provides advice on establishing and reorganizing corporate structures in a tax-efficient manner. He also advises Canadian charities on obtaining and maintaining status as a registered charity.

Larry Nevsky
Senior Associate, Toronto

A senior associate in Dentons' National Tax Group, Larry Nevsky's practice focuses on corporate tax advisory, tax planning, business structuring and tax dispute resolution.
Larry regularly advises both domestic and international clients with respect to income and indirect tax matters arising from mergers and acquisitions, corporate reorganizations, corporate finance transactions, cross-border transactions and from carrying on business in Canada. He also advises on matters relating to tax compliance and tax dispute matters, including voluntary disclosures, provincial and federal tax audits, objections and appeals.

Larry is a Chartered Accountant, having received his CPA, CA designation from the Institute of Chartered Accountants of Ontario, and he is a member of the Chartered Professional Accountants of Canada.

Tony Schweitzer
Partner, Dentons Canada LLP

As a partner with Dentons Canada LLP, Tony specializes in international tax. He advises corporations and individuals on cross-border tax structures, withholding taxes as well as transfer pricing issues. He also advises on Canadian corporate tax issues affecting private corporations as well as on deferred compensation arrangements. He advises pension funds on structuring and financing their domestic and international real estate and other investments and is the head of Dentons' Pension Fund Corporations practice group.