The Canada-U.S. Income Tax Treaty – Demystified

This course will help you further your understanding of the United States-Canada Tax Treaty. There is a tremendous amount of economic activity occurring cross-border between the U.S. and Canada. These transactions can give rise to both intended and unintended tax consequences. This seminar will cover the most critical issues such as residency, permanent establishments and the taxation of business profits. It will also review many other common situations dealt with in the Treaty. Where possible, planning opportunities will be discussed to help minimize the potential income taxes arising from cross-border transactions.

TOPICS INCLUDE:

• A review of the Treaty and when it can be applied
• Why determining residency is so important
• Permanent establishments (PE)
• Fixed Place PE
• Construction PE
• Agent PE
• Service PE
• Specific exclusions from PE
• What constitutes business profits and whether they are taxable?
• Taxation of employment income and remuneration earned by non-residents
• Taxability and reduced rates of tax on investment income
• Dividends
• Interest
• Royalties
• Rental income
• Capital gains
• Overview of Limitation of benefits – Anti-Treaty shopping provision

WHO WILL BENEFIT:

Experienced practitioners and other professionals with clients or employers conducting cross border business activities that want to strengthen or update their knowledge of the U.S.-Canada Tax Treaty. This course will help accounting professionals who has to deal with cross-border payments, planning or non-residents tax audits.