Tax memo: Payments to non-residents

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How new CRA guidelines and forms affect investment vehicles and other investors

This Tax memo discusses how new Canada Revenue Agency (CRA) administrative guidelines affect:

• certain investment vehicles (such as partnerships and hybrid entities, or their members) that own Canadian securities; and
• other investors in Canadian securities.

The guidelines specify the information Canadian payers must obtain to support withholding tax at a treaty-reduced rate on dividends, interest, management fees, rents and royalties paid to or for the benefit of non-residents.