The Canada-U.S. Tax Treaty - Text and Commentary

Canada and the United States share the world's largest economic relationship - cross-border trade generates over $400 billion (US) per year. Given the sheer number and variety of cross-border transactions, it is no surprise that the Canada-U.S. Tax Treaty is Canada's most significant treaty.

Butterworths The Canada-U.S. Tax Treaty: Text and Commentary is the first-ever detailed commentary on the entire treaty. Instead of relying on just the treaty text or searching for articles on aspects of the treaty, now you can turn to this comprehensive reference. Insightful commentary by renowned tax expert Vern Krishna will help you to plan the structure tax-effective transactions that avoid penalties and burdensome tax consequences.

With time-saving calculations and instructive examples, The Canada-U.S. Tax Treaty: Text and Commentary gives you a clear grasp of...

• Tax implications for different types of operations - in which country should tax returns be filed? What are the advantages and disadvantages of a permanent establishment? When must GST be charged?
• Anti-abuse issues - what constitutes treaty shopping? How are withholding taxes calculated? How do anti-avoidance rules differ between Canada and the US?
• Current issues - how will recent legislation and controversial budget proposals affect tax collecting practices and anti-avoidance rules?

Plus, these invaluable documents:

• Canada-U.S. Tax Treaty as amended including the integrated Protocols to date
• US Model Convention
• OECD Model Convention
• Income Tax Conventions Interpretations Act
• Convention on Mutual Administrative Assistance in Tax Matters