ARTICLE 6
U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States
The reference in paragraph 2 of Article XI (Interest) of the Convention to “15 per cent” shall be deleted and replaced by a reference to “10 per cent”.
Paragraph 3(d) of Article XI (Interest) of the Convention shall be deleted and replaced by the following:
“(d) The interest is beneficially owned by a resident of the other Contracting State and is paid with respect to indebtedness arising as a consequence of the sale on credit by a resident of
that other State of any equipment, merchandise or services except where the sale or indebtedness was between related persons; or”
- A new paragraph 9 shall be added to Article XI (Interest) of the Convention as follows: “9. The provisions of paragraphs 2 and 3 shall not apply to an excess inclusion with respect to a residual interest in a Real Estate Mortgage Investment Conduit to which Section 860 G of the United States Internal Revenue Code, as it may be amended from time to time without changing the general principle thereof, applies.”
Continue researching
Related topics
State and federal sources. Edit the document title or filters, then run your search.
Get a plain-English answer with a citation back to this text.
Ask AI about this code