ARTICLE II
U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States
Taxes Covered
This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied,
The existing taxes to which the Convention shall apply are:
(a) In the case of Canada, the taxes imposed by the Government of Canada under Parts I, XIII and XIV of the Income Tax Act; and
(b) In the case of the United States, the Federal income taxes imposed by the Internal Revenue Code.
- The Convention shall apply also to:
(a) Any identical or substantially similar taxes on income; and (b) Taxes on capital, which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes.
- Notwithstanding the provisions of paragraphs 2(b) and 3, the Convention shall apply to:
(a) The United States accumulated earnings tax and personal holding company tax, to the extent, and only to the extent, necessary to implement the provisions of paragraphs 5 and 8 of Article X (Dividends);
(b) The United States excise taxes imposed with respect to private foundations, to the extent; and only to the extent, necessary to implement the provisions of paragraph 4 of Article XXI (Exempt Organizations); and
(c) The United States social security taxes, to the extent, and only to the extent, necessary to implement the provisions of paragraph 4 of Article XXIX (Miscellaneous Rules).
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