Tax Memo: Canada-US Income Tax Treaty

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Fifth Protocol Enters into Force

On December 15, 2008, the fifth Protocol (the Protocol) to the Canada-US Income Tax Convention entered into force when Canada and the US notified each other that their respective applicable procedures have been satisfied.

This Tax Memo will consider the Protocol's entry into force under the following headings:

  • Coming-into-force dates
  • Withholding tax interest
  • Accounting implications

For more information on the Protocol's provisions, read the following PwC publications: