Transcription of TREASURY DEPARTMENT TECHNICAL EXPLANATION ... - IRS …
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TREASURY DEPARTMENT TECHNICAL EXPLANATION ... - IRS …
TREASURY DEPARTMENT TECHNICAL EXPLANATION OF THE CONVENTIONBETWEEN THE UNITED STATES OF AMERICA AND canada WITH RESPECT TOTAXES ON income AND ON CAPITAL SIGNED AT WASHINGTON, ONSEPTEMBER 26, 1980, AS AMENDED BY THE PROTOCOL SIGNED AT OTTAWA ONJUNE 14, 1983 AND THE PROTOCOL SIGNED AT WASHINGTON ON MARCH 28, EFFECTIVE DATE UNDER ARTICLE XXX: 1 JANUARY 1985 INTRODUCTIONThis is a TECHNICAL EXPLANATION of the Convention between the United States and Canadasigned on September 26, 1980, as amended by the Protocols signed on June 14, 1983 and March28, 1984. ("the Convention"). References are made to the Convention and Protocol betweenCanada and the United States with respect to income Taxes signed on March 4, 1942, asamended by the Convention signed on June 12, 1950, the Convention signed on August 8, 1956and the Supplementary Convention signed on October 25, 1966 (the "1942 Convention").
It was agreed that Part I of the Income Tax Act of Canada is a covered tax even though Canada has made certain modifications in the Income Tax Act after the signature of the Convention and before the signature of the 1983 Protocol. In particular, Canada has enacted a low flat rate tax on petroleum production (the PGRT) which, at the time of the ...
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