Interpretation of Canadian tax treaty

October 14, 2020


Q. I would like to have some assistance on how to interpret a tax treaty from Canada Article VII paragraph 1 for royalty payment. Supplier provided W-8BEN-E and US TIN number. The IRS technical explanation says:"ARTICLE VII Business Profits Paragraph 1 provides that business profits of a resident of a Contracting State are taxable only in that State unless the resident carries on business in the other Contracting State through apermanent establishment situated in that other State. If the…

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