Tax Memo: Fifth Protocol to the Canada-US Income Tax Treaty: Technical Explanation

On July 10, 2008, the US Treasury Department released the Technical Explanation of the fifth Protocol to the Canada-US Income Tax Convention to provide guidance with respect to many questions relating to the application of the Protocol.

PricewaterhouseCoopers has released a Tax Memo, which highlights the key points as well as some of the important questions that still remain unanswered.

Tax Memo: Fifth Protocol to the Canada-US Income Tax Treaty: Technical Explanation (115 KB) Download the full PDF Tax Memo.

For more information on the Protocol, see also our previously released Tax Memos:

• Canada-US Income Tax Treaty: Fifth Protocol Makes Major Changes (September 24, 2007); and
• Fifth Protocol to the Canada-US Income Tax Treaty-Reflections (October 3, 2007).