Interpretation of Canadian tax treaty

October 14, 2020

Share

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…

  Become A Member

Join IOFM today as a Professional, Business, or Enterprise Member — or upgrade your Starter Membership — to get access to this content and thousands of other Articles, Webinars, Expert Answers, Resource Downloads, and more!

Join Today


Naturally, this forum doesn’t allow the kind of full information exchange necessary for the Institute of Finance & Management (IOFM) to provide legal advice and the Expert is not a tax attorney in any event. Please understand that the nature of our responses are limited by these constraints as well as the site’s Terms of Use. If you have further questions or suggestions about how we can improve IOFM, please let us know. 
Ask The Expert is a member resource of IOFM and all advice provided is subject to site’s Terms of Use.

Subscribe to our Monthly Insider

You may unsubscribe from our mailing list at any time. Diversified Communications | 121 Free Street, Portland, ME 04101 | +1 207-842-5500