Bush on cross border tax issues

In a March 13 statement, President Bush announced he has sent to the Senate a U.S.-Canada protocol that would eliminate withholding taxes on cross-border interest payments and coordinate tax treatment of pension benefits for cross-border workers, with his recommendation that the Senate approve the protocol.

Do Your Tax Today and Save!

YY Consulting Tax Service is offering an exclusive discount for tax tips blog readers. Use coupon blog08 to get 10% discount off our standard rate. This offer ends on March 27, 2008.

Please give us a call at 604-764-9456 or email us at tax@yyconsulting.com.

Higher Canadian Dollar Random Thoughts

Canadians are getting a 20% raise! More people are driving down the south to pick up bargains. Crazy lineups these days.

However, if you are an American living in Canada or green card holder, you may encounter an unexpected surprise. If you haven't filed your US tax return, the border crossing guards now have access to these information and they may bar you from entry. It is no secret that CRA and IRS have been sharing tax information for years. But for the first time, these information are made available to the Homeland Security.

As a dual citizenship of Canada and US or a US green card holder, you have the obligation to file US tax return every year! We have a client who was born in the US and moved to Canada 25 years ago when he was 2. He found out the hard way when he was having trouble to apply for his US passport.

If you need help on filing your tax return, staff from YY consulting are specializing in the Canada-US cross border tax. And remember to check the border wait times before you go.

Alien Stories

Ever wondering about why you are being called alien in American tax system? It took me years to get used to the "alien" term. If I ever called you "alien", blame IRS for the brainwashing.

I personally went through the morphogenesis the moment I boarded the plane to the USA. Years have passed, I studied, worked and lived in US as an alien: first as a foreign student entitled all sort of rules and special treatments, then a non-resident alien, a resident alien and finally a dual-status alien!

Borrowed from IRS, here are some essential concepts that you should understand:

Resident Aliens

A resident alien's income is generally subject to tax in the same manner as a U.S. citizen. If you are a resident alien, you must report all interest, dividends, wages, or other compensation for services, income from rental property or royalties, and other types of income on your U.S. tax return. You must report these amounts whether from sources within or outside the United States.

Nonresident Aliens

A nonresident alien usually is subject to U.S. income tax only on U.S. source income. Under limited circumstances, certain foreign source income is subject to U.S. tax.

Dual-Status Aliens

You are a dual status alien when you have been both a resident alien and a nonresident alien in the same tax year.

Source of Income

A nonresident alien (NRA) usually is subject to U.S. income tax only on U.S. source income. Similar rules exist with respect to the source of income for withholding purposes

Income Types

In general, all income of a nonresident alien is Fixed, Determinable, Annual, Periodical (FDAP) income. However, certain kinds of FDAP income are considered to be effectively connected with a U.S. trade or business. These two types of income are taxed in different ways.
Reporting your Income in U.S. Currency

You must express the amounts you report on your U.S. tax return in U.S. dollars. If you receive all or part of your income, or pay some or all of your expenses in foreign currency, you must translate the foreign currency into U.S. dollars.
Tax Withholding on Foreign Persons

Payments of income to foreign persons are subject to special withholding rules. In particular, foreign athletes and entertainers are subject to substantial withholding on their U.S. source gross income. This withholding can be reduced by entering into a Central Withholding Agreement with the Internal Revenue Service.
Foreign Students and Scholars

Special rules apply to the taxation of foreign students and scholars which do not apply to other kinds of aliens.
Taxpayer Identification Numbers (TIN)

Anyone (including aliens) who files a U.S. federal tax return must have a Taxpayer Identification Number (TIN). In addition, aliens who request tax treaty exemptions or other exemptions from withholding must also have a TIN.
Tax Treaties

The U.S. tax liability of aliens is determined primarily by the provisions of the U.S. Internal Revenue Code. However, the United States has entered into certain agreements known as tax treaties with several foreign countries which oftentimes override or modify the provisions of the Internal Revenue Code.

If you need help on determining your taxation status in US, please contact a professional accountant.

Global business tax rates are dropping, but Canada's remain high

Corporate tax rates for G8 countries as of January, 2007

-----------------------------
Canada: 36.1
France: 33.3
Germany: 38.4
Italy: 37.3
Japan: 40.7
Russia: 24
Britain: 30
United States: 40

------------------------------

A related article:

Indirect Taxes Paying For Global Corporate Tax Competition, by Robert Lee,

Competition between countries to attract and keep foreign investment is continuing to drive down corporate tax rates across the world, although governments are clawing back revenues by increasing indirect taxes, which may require companies to shoulder greater compliance and accounting costs.

This is according to KPMG's corporate and indirect tax survey 2007, which, for the first time, tracks both corporate and indirect tax rate trends, shedding light on the way in which overall tax revenue calculations made by governments affect the relationship between tax authorities and business.

KPMG concludes that indirect taxes appear to be playing an increasingly important role in the revenue-gathering strategies of many countries around the world. This is a difficult policy for governments to follow, says the report, because the link between higher indirect taxes and higher prices is obvious to anyone who buys goods and services through higher prices, but the link between lower corporate tax rates and increased inward investment is less well understood. This has major implications for companies, their tax strategies and their accounting systems, the report noted.

Loughlin Hickey, Global Managing Partner of KPMG in the UK, observed that: "There is a clear tendency among nations in competition to attract and keep inward investment, to reduce their corporate tax rates and seek to make up the shortfall with increases in indirect taxes. This is rather than relying solely on growth brought about by corporate investment to expand this tax base. These tactics suggest that as well as attracting new investment, retaining current investments is a success in itself."

Hickey said that this was illustrated by Singapore, where Prime Minister Lee Hsien Loong had announced that a corporate tax cut would have to be paid for by an increase in GST. "If we bring down our corporate tax, every percentage point will cost us $400 million. It is big money," Lee told the Singapore Parliament last year, adding: "Therefore we must consider raising indirect taxes." Prime Minister Lee then went on to announce in his 2007 budget a 2% cut in corporate tax to 18% and a 2% increase in GST to 7%.

Rates of GST, VAT or its equivalent levy vary widely globally. The lowest rate is to be found in Aruba, where it is charged at 3%, the highest rates are to be found in Sweden, Denmark and Norway at 25%. On a regional basis, the average EU VAT rate at 19.5% is higher than the OECD average of 17.7%. The average rate across the Asia Pacific region is 10.8%, and in Latin America the average is 14.2%. However, KPMG says that it is difficult to draw direct comparisons between individual jurisdictions or regions because of the huge amount of special tax regimes and exceptions applied by many countries.

Across the OECD, the average rate of VAT/GST has held steady for the last six years, but the average corporate tax rate has drifted downwards by more than a tenth, from 31.4% to 27.8%. "So without changing rates, VAT/GST type taxes have become steadily more important as sources of revenue," the study noted.

In 2003, the last year for which figures are available, the average contribution of VAT/GST type taxes to government revenues across the OECD rose to 32.1%, having stayed between 31.2% and 31.7% for each of the previous five years. In some OECD countries, for example Mexico and Turkey, VAT/GST already contributed more than 50% to government budgets.

One of the advantages for governments of VAT/GST over corporate tax is that it provides a steady flow of revenues throughout the year rather than widely-spaced lump sums. However, this has major cost implications for companies which, effectively acting as a tax collector, must ensure that their accounting systems are up to date.

On the other hand, the survey shows that corporate tax rates are continuing to fall worldwide, but there are signs that this trend is slowing. Globally, average rates have decreased from 27.2% last year to 26.8% this year - significantly less than the major reductions seen in the late 1990s and early 2000s.

Of the 92 countries which participated in the KPMG survey, 18 reduced corporate tax rates, while two increased them. With such a small drop in average global rates, the report suggests that these adjustments were relatively slight, the major exception being Turkey, which slashed corporate tax by 10% to 20%. There were several significant reductions in the EU, where 17 out of the 27 member states cut rates, the largest being Bulgaria which decreased corporate tax by 5% to 10%. This took the EU average rate to 24%, 1.6% lower than last year. By comparison, the OECD average has fallen by less than 1% to 27.8%. Corporate tax cuts in India, Malaysia, and an increase of 2.5% in Sri Lanka leaves the Asia Pacific average broadly unchanged at 30%. Despite a material reduction of 8% in Aruba and smaller decreases in Columbia and the Dominican Republic, the Latin American average has fallen by just 0.5% to 28%.

"It would be interesting to conclude that corporate tax rates have reached their natural low points," noted Loughlin Hickey, "but it is clear that corporate tax rates in Europe are still being driven down, even as indirect taxes remain high."

However, while significant reductions are in the pipeline in the UK, Germany, Spain, Singapore and China and will be reflected in next year's report, Hickey concluded that: "It looks as if international tax competition has some way to go yet"

Cross-Border Taxation of Stock Options

Most large U.S. corporations have subsidiaries or other, operations in Canada, and many of these firms routinely send domestic employees to work temporarily in Canada. At the same time, many large U.S. firms offer stock options to their employees. Because of the differences in the way Canada and the U.S. tax stock options, expatriate employees are at risk of double taxation. For example, if an individual receives an option while employed by a Canadian firm and is treated as a Canadian resident for tax purposes, Canada often considers the option to be derived from employment with the Canadian firm, regardless of whether the option is vested. Therefore, a U.S. individual receiving Canadian options may move back to the U.S. prior to vesting in those options, yet Canada will treat income from the subsequent exercise of the options as Canadian-source income, subject to Canadian individual income tax (and perhaps social security tax).

Meanwhile, the U.S. will tax the full amount of income realized on exercise of the option and provide a foreign tax credit for income taxes paid to Canada. However, the U.S. will probably treat only a portion of the income from the exercise of the options as foreign-source; specifically, the U.S. will probably apportion the income between Canadian- and U.S.-source in proportion to the time worked in each country during the vesting period. This may result in double taxation.

In addition, the U.S. will impose FICA tax on the gain realized. Presumably, the U.S.-Canada Totalization Agreement could be invoked with respect to FICA tax and Canadian social security tax, but the employee may not have a certificate of coverage at the exercise date, or the certificate may have expired.

By Thomas, Jim Publication: The Tax Adviser

For employee stock options tax questions, please consult a professional accountant who are specialized in cross-border taxation to avoid double taxation and unexpected tax withholdings.

CRA Steps Up International Tax Audits

From KPMG report:

A recent report of the Auditor General (AG) indicates that the CRA has become increasingly concerned with the tax risks associated with international transactions. Although the AG found that the CRA is better able to identify potential non-compliance with the tax rules on international transactions, the CRA still needs to improve in several areas.

Given the CRA’s increased focus on international tax issues, including transfer pricing, Canadian corporations that undertake transactions with related parties in foreign jurisdictions face an ever-increasing probability of a transfer pricing audit by the CRA.

Consequently, corporations should be diligent in developing and implementing transfer pricing policies, as well as preparing appropriate transfer pricing documentation in an effort to reduce the likelihood of a transfer pricing adjustment in the event of a CRA audit.

CRA’s focus on international taxation issues

Aggressive tax planning, which includes international tax compliance, has been one of the CRA’s top four compliance priorities since 2004. As noted in the 2007 AG report, the CRA estimates that over 16,000 Canadian corporate taxpayers report some type of foreign transaction with related parties. These related-party transactions are estimated to involve more than $1.5 trillion in 2005.

The 2005 federal budget allocated $30 million annually to the CRA to address aggressive international tax planning. The CRA is using these funds to research tax avoidance and to increase the number of international auditors and tax avoidance auditors. As of March 31, 2006, the CRA had 320 international auditors and researchers and 210 non-resident auditors and program officers.

Auditors now use checklists and other planning tools to help them determine whether a corporation may be non-compliant and to begin transfer pricing and foreign affiliate audits. In addition, the time budgeted for an international audit of a large corporation has increased significantly. In 2006, the CRA’s total international audit reassessments had increased to $941 million from $778 million in 2001. The additional tax assessed on international transactions by large corporations was $729 million, compared to $300 million in 2001.

International auditor expertise and support

In its 2002 report, the AG expressed concern about the lack of adequately trained and experienced international auditors who were available to undertake transfer pricing and foreign affiliate audits.

A lack of adequate international audit experience was still observed by the AG in 2006. For example, in two Greater Toronto Area (GTA) tax services offices (TSOs), more than 40 percent of auditors had less than two years of international audit experience, while four of the ten international audit team leaders had less than one year of international team leader experience.
In an attempt to combat the lack of international audit experience, the CRA added 140 international and avoidance auditors and 39 experienced auditors to perform research studies. In addition, since 2002, the agency increased the total number of economists it employs to 16. However, the 2007 AG report notes that some TSOs continue to lack adequate training and experience in international audits, especially in the GTA.

The 2007 AG report noted that only 25% of audit recoveries came from the GTA, where more than 40% of large corporations report non-arm’s length transactions. It is suspected that tax recoveries in the GTA have been lost due to inconsistencies in the approach and coverage of international audits. The 2007 AG report also noted that, even though economists have been involved from the onset of the audit, they have limited experience in transfer pricing audits and lack industry-specific expertise.

Foreign documentation requests

The 2007 AG report revealed that the CRA has increased the use of information requests from foreign jurisdictions. However, the report concluded that auditors are still not making sufficient use of these provisions where taxpayers failed to provide the information voluntarily.

Tax Overseas Canadians

From Globe and Mail:
Tax overseas Canadians, Ottawa told

Critics urge special tax for overseas Canadians
Government must demand more in return for generous passport policy, observers say

Some call the Canadian passport an $87 get-out-of-jail-free card. Others see it as emergency evacuation insurance.

As Ottawa finally begins to review Canada's citizenship policy -- one of the most generous in the world -- critics are calling for a special tax for overseas Canadians.

"People want all the benefits of being Canadian, but none of the burden," said Richard Kurland, a lawyer and immigration policy analyst. "Non-resident citizens should not have a free ride -- business class -- at taxpayers' expense, by flashing a Canadian passport."

Added Don DeVoretz, an economist at Vancouver's Simon Fraser University: "The time has come to look at the citizenship policy and ask, does it serve Canada's interests?"

This summer's $94-million evacuation of 15,000 Lebanese-Canadians from war-torn Lebanon finally prompted Ottawa to announce a review of Canada's citizenship policy. Immigration Minister Monte Solberg won't divulge details about the review, but he has said it is time to review the obligations of citizens who live abroad while drawing on Canada's social programs.

Kurland advocates the introduction of a special new tax for non-resident citizens. Canadians who have been living overseas for more than five years should pay $500 for a passport, he said.

This idea has also been endorsed by John Chant, a retired Simon Fraser University economist, in a study titled the Passport Package, released this month by the C.D. Howe Institute.

"The costs of the non-resident passport package should be shifted from resident Canadians who pay taxes to non-resident citizens who benefit but pay no taxes," Prof. Chant said in an interview.

Such a tax would raise about $200-million a year, based on the estimate that 80% of the 2.7 million overseas Canadians would choose to maintain their citizenship.

The policy would be less cumbersome and bureaucratic than requiring Canadians living abroad to pay income taxes.

"I have spoken to non-governmental organizations who work with South Asians, and they all think this is very fair," Kurland said. "Call it the insurance passport."

There has been a recent rush on applications for passports, as the Jan. 23 deadline approaches for new U.S. rules requiring Canadians to show passports when they fly south.

Canada's current policy, designed to attract newcomers, allows immigrants to become citizens after just three years of residency -- with no requirement to relinquish previous passports.

Non-resident Canadians do not have to pay income tax. Babies born to tourists are also entitled to full citizenship. People can acquire citizenship through ancestry as well, qualifying if a parent was Canadian -- even if this parent never lived in Canada.

This generous policy, meant to lure newcomers, has in many cases actually served to accelerate their departure. Today, an estimated 8% of all Canadians (2.7 million) live outside the country, 1.7 million of them permanent residents elsewhere, according to the Asia Pacific Foundation of Canada. Forty-four% live in the United States; 24% in Asia and 18% in Europe. There are currently 300,000 Canadians in Hong Kong alone.

In his study, Prof. Chant notes that overseas Canadians have a range of government benefits that he calls the "passport package."

The package includes not just one-time evacuations, but a whole list of benefits:

* They pay resident tuition fees and receive university financial assistance;
* Their dependents can become Canadian citizens;
* They have health-care benefits;
* They are eligible for the prisoner transfer program;
* They receive consular services, free entrance into Canada and visa exemptions to travel to many other countries.

Kurland added that if there was political upheaval in Taiwan, Hong Kong or mainland China, the impact on Canada could be enormous in terms of evacuation and resettlement costs. "Those evacuated from Lebanon this summer were given return tickets and within two months, half had returned," he pointed out. "It's time they shared the cost of this."

John Kirton, a University of Toronto political scientist, believes the Canadian diaspora should be considered an asset, not a financial drain. "They are ambassadors promoting Canadian culture and values abroad and also fostering family business networks," he said. "It is the quintessential Canadian experience to carry more than one passport."

Others, however, would like to see overseas Canadians become more politically engaged. Prof. DeVoretz suggests they be encouraged to vote, and serve jury duty. "I'd like to see more political awareness among non-resident Canadians," he said.

Prof. DeVoretz recently returned from Nashan, China, where he interviewed 500 Canadians of Chinese origin about why they decided to return to their country of origin. He discovered that most never intended to stay in Canada. "They just wanted the passports," he said.

"They were fairly successful in Canada but they are more successful in Hong Kong. The conditions had to be right for their return."

They cannot be faulted for taking advantage of a liberal citizenship policy, but the example proves the point, he said: Ottawa needs to ask whether the current citizenship policy is in the interests of tax-paying Canadians.

Around the world

* 150 countries allow dual citizenship.
* China, Cuba and South Korea do not.
* Germany allows dual citizenship, but makes people choose loyalty to one country by the age of 19.
* The United States requires non-resident Americans to file income-tax returns.
* Denmark does not automatically grant citizenship to children of Danish immigrants.
* In India, dual citizens may not vote, and non-resident citizens must file income-tax returns.

Canada's Tax Treaties with other countries

In Force
Algeria

The Canada-Algeria Income Tax Convention, as signed on February 28, 1999. For further details, consult News Release 2001-004.
- return -
Argentina

The Canada-Argentina Income Tax Convention, as signed on April 29, 1993
- return -
Armenia

The Canada-Armenia Tax Convention as signed on June 29, 2004.
- return -
Australia

The new Canada-Australia Income Tax Convention, as signed on May 21, 1980 and amended by the Protocol signed on January 23, 2002.
The Canada-Australia Protocol, as signed on January 23, 2002.
The Canada-Australia Income Tax Convention, as signed on May 21, 1980.
- return -
Austria

The Canada-Austria Income Tax Convention, as signed on December 9, 1976 and amended by a Protocol signed on June 15, 1999.
- return -
Azerbaijan

The Canada-Azerbaijan Income Tax Convention as signed on September 7, 2004.
- return -
Bangladesh

The Canada-Bangladesh Income Tax Convention, as signed on February 15, 1982.
- return -
Barbados

The Canada-Barbados Income Tax Agreement, as signed on January 22, 1980.
- return -
Belgium

The new Canada-Belgium Income Tax Convention as signed on May 23, 2002. This treaty entered into force on October 6, 2004, and replaces the treaty signed in 1975.
The Canada-Belgium Income Tax Convention, as signed on May 29, 1975.
- return -
Brazil

The Canada-Brazil Income Tax Convention, as signed on June 4, 1984.
- return -
Bulgaria

The Tax Convention between Canada and the Republic of Bulgaria, as signed on March 3, 1999.
- return -
Cameroon

The Canada-Cameroon Income Tax Convention, as signed on May 26, 1982.
- return -
Chile

The Convention between Canada and the Republic of Chile, as signed on January 21, 1998.
- return -
China (PRC)

The Canada-China Income Tax Agreement as signed on May 12, 1986.
- return -
Croatia

The Agreement Between Canada and the Republic of Croatia, as signed on December 9, 1997.
- return -
Cyprus

The Canada-Cyprus Tax Convention, as signed on May 2, 1984.
- return -
Czech Republic

The new Convention between Canada and the Czech Republic, as signed on May 25, 2001. This treaty entered into force on May 28, 2002. For further details, consult News Release 2001-052.
The Canada-Czechoslovakia Tax Convention, as signed on August 30, 1990.
- return -
Denmark

The Convention Between Canada and the Kingdom of Denmark, as signed on September 17, 1997.
- return -
Dominican Republic

The Canada-Dominican Republic Tax Convention, as signed on August 6, 1976.
- return -
Ecuador

The Convention Between the Government of Canada and the Government of the Republic of Ecuador, as signed on June 28, 2001. For further details, consult News Release 2002-004.
- return -
Egypt

The Canada-Egypt Tax Convention, as signed on May 30, 1983.
- return -
Estonia

The Canada-Estonia Tax Convention as signed on June 2, 1995. For further details, consult News Release 1996-002.
- return -
Finland

The new Canada-Finland Income Tax Convention as signed on July 20, 2006.
The Canada-Finland Income Tax Convention, as signed on May 28, 1990.
- return -
France

The Canada-France Income Tax Convention, as signed on May 2, 1975 and amended by a Protocol signed on January 16, 1987 and a Protocol signed on November 30, 1995.
- return -
Germany

The new Agreement between Canada and the Federal Republic of Germany, as signed on April 19th, 2001. For further details, consult News Release 2002-030.
The Agreement between Canada and the Federal Republic of Germany, as signed on July 17, 1981.
- return -
Guyana

The Canada-Guyana Income Tax Convention, as signed on October 15, 1985.
- return -
Hungary

The Canada-Hungary Income Tax Convention, as signed on April 15, 1992 and modified by a Protocol signed on May 3, 1994.
- return -
Iceland

The Convention Between Canada and the Republic of Iceland, as signed on June 19, 1997.
- return -
India

The Canada-India Income Tax Agreement, as signed on January 11, 1996 (DFAIT web site).
- return -
Indonesia

The consolidated version of the Canada-Indonesia Income Tax Convention, as signed on January 16, 1979 and modified by a Protocol signed in April 1, 1998.
- return -
Ireland

The new Canada-Ireland Income Tax Convention, as signed on October 8, 2003.
The Canada-Ireland Income Tax Convention, as signed on November 23, 1966.
- return -
Israel

The Canada-Israel Income Tax Convention, as signed on July 21, 1975.
- return -
Italy

The Canada-Italy Income Tax Convention, as signed November 17, 1977 as modified by a Protocol signed on March 20, 1989.
- return -
Jamaica

The Canada-Jamaica Income Tax Agreement, as signed on March 30, 1978.
- return -
Japan

The Canada-Japan Income Tax Convention, as signed on May 7, 1986; amended by a Protocol signed on February 19, 1999 and entered into force on December 14, 2000. For further details, consult News Release 2000-088.
- return -
Jordan

The Canada-Jordan Income Tax Convention signed on September 6, 1999. For further details, consult News Release 2001-005.
- return -
Kazakhstan

The Convention between the Government of the Republic of Kazakhstan and the Government of Canada, as signed on September 25, 1996.
- return -
Kenya

The Canada-Kenya Income Tax Agreement, as signed on April 27, 1983.
- return -
Korea

The new Canada-Korea Income Tax Convention, as signed on September 5, 2006.
The Canada-Korea Income Tax Convention, as signed on February 10, 1978.
- return -
Kuwait

The Canada-Kuwait Income Tax Agreement, as signed on January 28, 2002.
- return -
Kyrgyzstan

The Canada-Kyrgyzstan Income Tax Convention signed on June 4, 1998. For further details, consult News Release 2001-003.
- return -
Latvia

The Convention Between the Republic of Latvia and Canada, as signed on April 26, 1995.
- return -
Lithuania

The Convention between the Government of the Republic of Lithuania and the Government of Canada, as signed on August 29, 1996.
- return -
Luxembourg

The Convention signed on September 10, 1999 between Canada and the Grand Duchy of Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital entered into force on October 17, 2000. For further details, consult News Release 2000-084.
- return -
Malaysia

The Canada-Malaysia Income Tax Agreement, as signed on October 15, 1976.
- return -
Malta

The Canada-Malta Income Tax Agreement, as signed on July 25, 1986.
- return -
Mexico

The Convention Between the Government of Canada and the Government of the United Mexican States, as signed on April 8, 1991.
- return -
Moldova

The Canada-Moldova Income Tax Convention, as signed on July 4, 2002.
- return -
Mongolia

The Canada-Mongolia Income Tax Convention, as signed on May 27, 2002.
- return -
Morocco

The Canada-Morocco Income Tax Convention, as signed on December 22, 1975.
- return -
Netherlands

The Canada-Netherlands Income Tax Convention, as signed on May 27, 1986 and amended by the Protocols signed on March 4, 1993 and August 25, 1997.
- return -
New Zealand

The Canada-New Zealand Income Tax Convention signed on May 13, 1980.
- return -
Nigeria

The Agreement Between the Government of Canada and the Government of the Federal Republic of Nigeria, as signed on August 4, 1992.
- return -
Norway

The new Canada-Norway Income Tax Convention, as signed on July 12, 2002.
The Canada-Norway Income Tax Convention, as signed on November 23, 1966.
- return -
Oman

The Canada-Oman Tax Agreement as signed on
June 30, 2004.
- return -
Pakistan

The Canada-Pakistan Income Tax Convention, as signed on February 24, 1976.
- return -
Papua New Guinea

The Canada-Papua New Guinea Income Tax Agreement, as signed on October 16, 1987.
- return -
Peru

The Canada-Peru Income Tax Convention, as signed on July 20, 2001.
- return -
Philippines

The Canada-Philippines Income Tax Convention, as signed on March 11, 1976.
- return -
Poland

The Canada-Poland Income Tax Convention, as signed on May 4, 1987.
- return -
Portugal

The Convention between Canada and the Portuguese Republic, as signed on June 14, 1999. For further details, consult News Release 2001-087.
- return -
Republic of the Ivory Coast

The Canada - Ivory Coast Income Tax Convention, as signed on June 16, 1983.
- return -
Romania

The new Canada-Romania Income Tax Convention as signed on April 8, 2004. This treaty entered into force on December 31, 2004, and replaces the treaty signed in 1978.
The Canada-Romania Income Tax Convention, as signed on November 20, 1978.
- return -
Russia

The Canada-Russia Income Tax Agreement, as signed on October 5, 1995 (DFAIT web site).
- return -
Senegal

The Canada-Senegal Income Tax Convention, as signed on August 2, 2001.
- return -
Singapore

The Canada-Singapore Income Tax Convention, as signed on March 6, 1976.
- return -
Slovak Republic

The Canada-Slovak Republic Income Tax Convention, as signed on May 22, 2001. For further details, consult News Release 2002-002.
- return -
Slovenia

The Convention Between the Government of Canada and the Government of the Republic of Slovenia as signed on September 15, 2000
- return -
South Africa

The Canada-South Africa Income Tax Convention, signed on November 27, 1995 (DFAIT web site).
- return -
Spain

The Canada-Spain Income Tax Convention, as signed on November 23, 1976 (DFAIT web site).
- return -
Sri Lanka

The Canada - Sri Lanka Income Tax Convention, as signed on June 23, 1982.
- return -
Sweden

The Convention between Canada and Sweden, as signed on August 27, 1996 (DFAIT web site).
- return -
Switzerland

The Convention between Canada and Switzerland, as signed on May 5, 1997.
- return -
Tanzania

The Canada-Tanzania Income Tax Agreement, as signed on December 15, 1995 (DFAIT web site).
- return -
Thailand

The Canada-Thailand Income Tax Convention, as signed on April 11, 1984.
- return -
Trinidad and Tobago

The Convention between the Government of Canada and the Government of the Republic of Trinidad and Tobago, as signed on September 11, 1995.
- return -
Tunisia

The Canada - Tunisia Income Tax Convention, as signed on February 10, 1982.
- return -
Ukraine

The Canada-Ukraine Income Tax Convention, as signed on March 4, 1996 (DFAIT web site).
- return -
United Arab Emirates

The Tax Convention Between Canada and the United Arab Emirates as signed on June 9, 2002.
- return -
United Kingdom

The Canada-United Kingdom Protocol, as signed on May 7, 2003.
The Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland, as signed on September 8, 1978 and amended by a Protocol signed on April 15, 1980 and a Protocol signed on October 16, 1985.
- return -
United States

The Convention between Canada and the United States of America, as amended by the protocols signed on June 14, 1983, March 28, 1984, March 17, 1995 and July 29, 1997.
- return -
Uzbekistan

The Convention between the Government of Canada and the Government of the Republic of Uzbekistan, as signed on June 17, 1999.
- return -
Venezuela

The Tax Convention Between Canada and Venezuela, as signed on July 10, 2001.
- return -
Vietnam

The Agreement Between the Government of Canada and the Government of the Socialist Republic of Vietnam, as signed on November 14, 1997.
- return -
Zambia

The Canada - Zambia Income Tax Convention, as signed on February 16, 1984.
- return -
Zimbabwe

The Canada - Zimbabwe Income Tax Convention, as signed on April 16, 1992.
- return -
http://www.fin.gc.ca/treaties/in_force-e.html