International corporate structures and the new protocol to the Canada-US Income Tax Convention

Files

International Corporate Structures and the New Protocol to the Canada-US Income Tax Convention - January 1996.pdf (1.4 MB)

Date

1996-01

Authors

O'Brien, Martha

Journal Title

Journal ISSN

Volume Title

Publisher

The Advocate

Abstract

The Canada-US Tax Convention contains limitation of benefits rules which, following the ratification of the 2007 Protocol, will apply to limit the application of the Convention to residents of the US and well as of Canada. This article analyzes the effects of the limitation on benefits rules contained in the third protocol of 1995, in relation to benefits available to Canadian residents.

Description

Keywords

taxation, limitation of benefits, Canada, United States

Citation

"International corporate structures and the new protocol to the Canada-U.S. Income Tax Convention”, The Advocate, Vol. 54, Part 1, January 1996, 43 - 56.

URI

http://hdl.handle.net/1828/1022

Collections

Faculty Publications (Law)
 
University of Victoria Libraries

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