The New Canada-U.S. Tax Treaty

In June 2009 I published a piece on the then-newly agreed Fifth Protocol to the Canada-U.S. Tax Convention for the Hamilton Law Association Journal. It discusses withholding tax on cross-border interest, treaty benefits for U.S. limited liability corporations (“LLCs”), binding arbitration for treaty matters, and the “limitation of benefits” (LOB) provisions for hybrid entities including Canadian ULCs.

The issue for treaty benefits for Canadian ULCs remains an issue in many circumstances. US entities with a Canadian ULC in their corporate chart should discuss how to manage that situation if they have not already done so.


Written by Craig Burley

Craig is a tax lawyer in private practice in Hamilton, Ontario. Call Craig at (905) 296-3378 to discuss issues that you think may need independent tax advice. In addition to tax, Craig writes and works publicly on a number of other issues related to law, justice, and public affairs.