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 […]
Permanent Establishments Through Related Corporations Under the OECD Model Treaty
As global tax authorities tighten their grip on multinational enterprises, one contentious issue has taken center stage: can a subsidiary create a “permanent establishment” for its parent company? In Permanent Establishments Through Related Corporations Under the OECD Model Treaty, Matias Milet explores this complex and increasingly high-stakes question. Tracing the debate from the League of […]