Webinar: The Limitation on Benefits provisions contained in Article XXIXA of the Canada - US Tax Treaty
This 90 minute webinar will analyze the legal framework and application of the Limitation on Benefits provisions in Article XXIXA of the Canada-US Tax Treaty. Limitations on Benefits provisions of the Canada-US Tax Treaty in the Fifth Protocol have been implemented to combat treaty shopping and prevent third country residents from obtaining benefits under the Canada-US Tax Treaty by routing Canadian-source income through US-based entities.
Date: Wednesday, March 31, 2010
Time: 12:pm-1:30pm EST
This 90 minute webinar will analyze the legal framework and application of the Limitation on Benefits provisions in Article XXIXA of the Canada-US Tax Treaty. Limitations on Benefits provisions of the Canada-US Tax Treaty in the Fifth Protocol have been implemented to combat treaty shopping and prevent third country residents from obtaining benefits under the Canada-US Tax Treaty by routing Canadian-source income through US-based entities.
The webinar will discuss various scenarios based on the 2008 Technical Explanations and recent CRA pronouncements illustrating the definition of qualifying person, as well as the application of active trade and business test and derivate benefits tests, as these provisions apply to the income paid to individuals, corporations, and fiscally transparent entities.
Who Should Attend
The webinar is an LOB-101 presentation designed for Canadian tax advisors with foreign clients doing business in Canada and clients carrying on business in the U.S. or abroad.
For more information on the webinar, please click here or contact me at:
Vitaly Timokhov
(E) vitaly.timokhov@taxchambers.ca
(T) 416 847 7300
(W) http://www.taxchambers.ca
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