Policy Forum: The Fifth Protocol to the Canada-US Income Tax Treaty and the 2006 US Model Treaty—How Do They Compare?
The Fifth Protocol to the Canada–US tax treaty, signed in September 2007, represents one of the most significant updates to the cross-border tax framework in decades. In this article, Virginia Davies, Janice McCart, and Willard Taylor compare the protocol with the 2006 US Model Treaty, highlighting key differences in areas such as permanent establishments, business […]