Canada-US protocol: It’s finally time to play ball
October 08, 2007
Rene Fleming and Sandra Goldberg of Deloitte in Ottawa comment on binding arbitration in the long-awaited Canada-US protocol
After almost 10 years of negotiations between their two nations, Canadian finance minister Jim Flaherty and US Secretary of the Treasury Henry Paulson signed the fifth protocol to the Canada-US Income Tax Convention on September 17. The protocol eliminates withholding tax on cross-border interest payments and extends treaty benefits to limited liability corporations, among many significant changes. One of the most highly anticipated provisions is the introduction of a long-awaited binding arbitration clause that should be of substantial assistance in ensuring that taxpayers are not subject to double taxation.
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