Canada-U.S. Tax Treaty: Making Trade Less Taxing

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Canada-U.S. Tax Treaty: Making Trade Less Taxing


TaxChambers LLP and True Partners Consulting cordially invite you to attend a joint presentation on the Canada-U.S. Tax Treaty.

The Canada-US Income Tax Treaty is a reflection of the profound and extensive economic and social ties between Canada and the US. It has been one of the most-negotiated international treaties in place, and continues to be an invaluable tool for cross-border tax planners to eliminate double-taxation, both for individuals and corporations engaged in exporting goods, services, or investing in the U.S. or Canada.

In our brief presentation, we will focus on the general structure of the Canada-U.S. Tax Treaty, including recent changes made as a result of the implementation of the 5th Protocol to the Treaty. We will also highlight major tax reduction provisions of the Treaty and corresponding provisions of Canadian tax laws that allow U.S. investors to reduce their exposure to Canadian income taxation. In particular, we will focus on the following topics:

· Taking profits out of Canada tax-free: business income, dividends, interest and royalties

· Canadian tax residency and permanent establishment: tips on avoiding a tax nexus in Canada

· Entitlement to Treaty benefits: beneficial ownership and limitation on benefits (LOB) as applied by the Canadian tax authorities.

The 30 min presentation will be followed by a cocktail reception.


Vitaly Timokhov, JD, LL.M. (Taxation, NYU)– a Canadian senior editor and author of the Tax Advisor’s Guide to the Canada-U.S. Tax Treaty. Vitaly is a member of TaxChambers LLP, a Toronto boutique tax law firm focused primarily on cross-border tax planning. Prior to establishing TaxChambers LLP, Vitaly was a member of International Tax Services at Ernst & Young and worked at the Canadian Tax Desk at the firm’s New York office, personally handling transactions between Canada and the U.S. totalling in excess of two hundred billion dollars.

When: Thursday, June 21, 2012 at 5:30 PM to 7:30 PM.

Where: True Partners Consulting, 225 West Wacker Drive, Suite 1600, Chicago, IL 60606

RSVP –Laura Booth at Laura.Booth@TPCtax.com