Vitaly Timokhov will present a 2.5 hour workshop at the 63rd Annual Tax Conference in Montreal on November 27, 2011 on Canada-US Tax Convention – Limitation on Benefits. Vitaly is an editor and author of the Tax Advisor’s Guide to the Canada-U.S. Tax Treaty, a 2-volume treatise on the Canada-U.S. Tax Treaty published by Carswell Reuters Canada.
Article XXIXA (Limitation on Benefits) is an anti-avoidance rule built into the Canada-U.S. Tax Treaty. The purpose of this provision is to prevent treaty shopping. This broad goal is achieved by denying the benefits of the Treaty to any U.S. recipient of Canadian-sourced income unless the recipient is a qualifying person, satisfied a number of complex tests set out in the LOB Article, or obtained relief from Canadian tax authorities. The workshop will focus on the following subjects:
For details and registraiton, see http://www.ctf.ca/ctfweb/EN/Conferences_Events/2011/Programs/2011ACProgram.asp
TaxChambers LLP is collaborating with Andersen Global® in Canada.