ARTICLE X

U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States

Paragraph 2 of Article XXI (Exempt Organizations) shall be deleted and replaced by the following: “2. Subject to the provisions of paragraph 3 income referred to in Article X (Dividends) and XI (Interest) derived by:

(a) A trust, company or other organization which is resident in a Contracting State, generally exempt from tax in a taxable year in that State and constituted and operate exclusively to administer or provide benefits under one or more funds or plans established to provide pension, retirement or other employee benefits; or

(b) A trust, company or other organization which is resident in Contracting State, not taxed in a taxable year in that State and constituted and operated exclusively to earn income for the benefit of an organization referred to in subparagraph (a); shall be exempt from tax in the taxable year in the other Contracting State.”

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▸Contents — U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980

U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980

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