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