Navigating International Tax Developments: The New Fifth Protocol to the Canada-US Income Tax Treaty

This webcast features presentations from Navigating International Tax Developments: The New Fifth Protocol to the Canada-US Income Tax Treaty, a series of cross-Canada seminars informing US and Canadian multinational companies and individual taxpayers on the Treaty’s new protocol.

PwC’s seminar leaders share insight and answer questions about the recently signed Fifth Protocol to the Canada-US Income Tax Treaty and its effect on individual taxpayers and Canadian and US multinationals doing business in the US and Canada respectively. Our PwC specialists help you navigate business issues arising from the Treaty’s new protocol in the context of other recent and pending tax developments.

To view the archived nine-part webcast of this presentation, visit Navigating International Tax Developments: The New Fifth Protocol to the Canada-US Income Tax Treaty.

The presentation’s topics cover:

  • Withholding Tax and Permanent Establishment (PE) Issues
  • LLCs, Partnerships and Hybrid Entities
  • The new Canadian Limitations on Benefits (LOB) Clause
  • Transfer Pricing
  • Personal Taxes
  • Legislative Proposals
  • Interest Deductibility
  • Foreign Affiliate Technical Amendments
  • Functional Currency Election

Featured speakers include:

  • Kim Curtis, partner, Human Resource Services, Toronto
  • Steve Dunk, partner, Corporate Tax, Toronto
  • Liam Fitzgerald, senior manager, Corporate Tax, Toronto
  • Elizabeth Johnson, partner, Tax, Toronto
  • Eric Lockwood, associate partner, Corporate Tax, Toronto
  • Mike Maikawa, partner, Corporate Tax, Toronto
  • Andrew McAskile, partner, Corporate Tax, Toronto
  • Andy McCrodan, partner, Corporate Tax, Toronto
  • Nick Pantaleo, partner, Corporate Tax, Toronto
  • Victor Romberg, partner, Human Resource Services, Toronto




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Of further interest
  • Tax Memo: Canada-US Income Tax Treaty: Fifth Protocol Makes Major Changes

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