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ARTICLE · 11 OCTOBER 2007

New Protocol To The Canada-U.S. Income Tax Convention

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The Honourable Jim Flaherty, Minister of Finance, and Henry M. Paulson, Jr., U.S. Secretary of the Treasury, have signed the Fifth Protocol (the “Protocol”) to the Canada-U.S. Tax Convention (the “Convention”) on September 21, 2007.

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Ken Snider
Ken Snider
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The Honourable Jim Flaherty, Minister of Finance, and Henry M. Paulson, Jr., U.S. Secretary of the Treasury, have signed the Fifth Protocol (the "Protocol") to the Canada-U.S. Tax Convention (the "Convention") on September 21, 2007. The Protocol has taken approximately ten years to negotiate and provides many benefits for both Canadians and Americans.

We would like to highlight certain of the important changes introduced by the Protocol. Our in-depth analysis of the Protocol and the implications in respect of cross-border transactions will be forwarded by email in the near future.

Elimination Of Withholding Tax On Cross-Border Interest

The current Convention generally reduces withholding tax on interest to 10%.

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