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Canada
Supports U.S. Technical Explanation of the Fifth Protocol to the Canada-United
States Income Tax Convention
The Honourable Jim
Flaherty, Minister of Finance, indicated Canadian agreement with the United
States Treasury Department’s Technical Explanation to the Fifth Protocol to the
Canada-United States Tax Convention. Canada ratified the Protocol on December
14, 2007, when Bill S-2 received Royal Assent.
It is the usual practice of the U.S. Treasury Department to prepare a technical
explanation of tax treaties and protocols subject to formal ratification. While
it is not customary for Canada to issue such an explanation, Canada was given an
opportunity to review and comment on the U.S. document. The Minister indicated
that Canada agrees that the Technical Explanation accurately reflects
understandings reached in the course of negotiations with respect to the
interpretation and application of the various provisions in the Protocol.
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