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Title:
Alert: Fifth Protocol to the Canada-US Income Tax Convention
Author:
Brian D. Segal, Peter M. Daub, Carol A. Dunahoo, Jonathan Garbutt
Contact Information:
Marie E. Caylor
,
Carol Alexander
Publication Date:
September
2007
Publication Type:
Newsletter/Alert
Practice/Industry:
Tax; General Tax Planning; International Private Banking; Real Estate Tax; State & Local Tax; Supply Chain Tax Planning; Tax Advice for M&A & Corporate Restructuring; Tax Controversy & Litigation; Transfer Pricing; VAT/Indirect Tax
Region:
North America
Office:
Chicago; Dallas; Houston; Miami; New York; Palo Alto; San Diego; San Francisco; Toronto; Washington DC
Description:
On September 21, 2007, the Canadian and US governments signed the fifth protocol (the "Protocol") to the Canada-US Income Tax Convention (the "Treaty"). This client alert discusses the recently signed Protocol and focuses on the amendments to the Treaty, it is likely to be of immediate interest to a broad range of entities and persons including US LLCs and hybrid entities, US or Canadian persons lending cross-border, and US or Canadian corporations embroiled in cross-border transfer pricing disputes.
Price and Currency:
Complimentary
Publication/Link
:
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