TAX CONVENTIONS

Rev. Rul. 2002–16, page 740. This ruling confirms that the Netherlands investment yield tax is a tax for which a credit may be allowed under Article 25(4) of the U.S.–Netherlands income tax convention because, under Article 2(2), it is substantially similar to a prior Dutch tax that was a covered tax under the convention.

Rev. Proc. 2002–23, page 744. This document describes new procedures under Article XVIII(7) of the U.S. – Canada income tax convention whereby U.S. taxpayers may elect to defer U.S. income taxation on income accruing in certain Canadian pension plans until a distribution is made from such plans. Rev. Proc. 89–45 superseded.