Federal tax law
U.S. Income Tax Treaty — Canada Technical Explanation - 1980
Federal tax law and IRS guidance as published — verbatim and citable.
- Edition
- 2026-10-03
- Last updated
- 2026-10-04
- Contents
- 97 sections
- Jurisdiction
- United States
Contents
- ARTICLE I
- Article I provides that the Convention is generally applicable to persons who are
- ARTICLE II
- Article II does not specifically refer to interest, fines and penalties. Thus, each
- ARTICLE III
- Article III provides definitions and general rules of interpretation for the Convention.
- ARTICLE IV
- Article IV provides a detailed definition of the term "resident of a Contracting State." The
- ARTICLE V
- ARTICLE VI
- ARTICLE VII
- ARTICLE VIII
- ARTICLE IX
- ARTICLE X
- Article X does not apply to dividends paid by a company which is not a resident of either
- ARTICLE XI
- ARTICLE XII
- ARTICLE XIII
- ARTICLE XIV
- Article XIV concerns the taxation of income derived by an individual in respect of the
- ARTICLE XV
- Article XV states that its provisions are overridden by the more specific rules of Article
- ARTICLE XVI
- Article XVI concerns income derived by a resident of a Contracting State as an
- ARTICLE XVII
- Article XVII confirms that a Contracting State may require withholding of tax on account
- Article XVIII A of the 1942 Convention authorizes the issuance of regulations to specify
- ARTICLE XVIII
- ARTICLE XIX
- Article XIX provides that remuneration, other than a pension, paid by a Contracting State
- ARTICLE XX
- Article XX provides that a student, apprentice, or business trainee temporarily present in a
- ARTICLE XXI
- ARTICLE XXII
- ARTICLE XXIII
- ARTICLE XXIV
- ARTICLE XXV
- Article XXV substantially broadens the protection against discrimination provided by the
- ARTICLE XXVI
- ARTICLE XXVII
- ARTICLE XXVIII
- Article XXVIII states that nothing in the Convention affects the fiscal privileges of
- ARTICLE XXIX
- ARTICLE XXX
- ARTICLE XXXI
- ARTICLE 1
- Article 1 of the Protocol amends Article II (Taxes Covered) of the Convention. Article II
- Article 1 of the Protocol also makes minor clarifying, nonsubstantive amendments to
- ARTICLE 2
- ARTICLE 3
- Article 3 of the Protocol amends Article IV (Residence) of the Convention. It clarifies the
- Article 3 of the Protocol adds a sentence to paragraph 3 of Article IV of the current
- ARTICLE 4
- Article 4 of the Protocol amends paragraphs 3 and 4 of Article IX (Related Persons) of the
- Article 4 of the Protocol amends paragraphs 3 and 4 of Article IX to prevent taxpayers
- ARTICLE 5
- Article 5 of the Protocol amends Article X (Dividends) of the Convention, paragraph 1 of
- ARTICLE 6
- Article 6 of the Protocol amends Article XI (Interest) of the Convention. Paragraph 1 of
- ARTICLE 7
- Article 7 of the Protocol modifies Article XII (Royalties) of the Convention by expanding
- ARTICLE 8
- Article 8 of the Protocol broadens the scope of paragraph 8 of Article XIII (Gains) of the
- ARTICLE 9
- Article 9 of the Protocol amends Article XVIII (Pensions and Annuities) of the
- ARTICLE 10
- Article 10 of the Protocol amends Article XXI (Exempt Organizations) of the Convention.
- ARTICLE 11
- Article 11 of the Protocol adds a new paragraph 3 to Article XXII (Other Income) of the
- ARTICLE 12
- Article 12 of the Protocol amends Article XXIV (Elimination of Double Taxation) of the
- ARTICLE 13
- Article 13 of the Protocol amends Article XXV (Non-Discrimination) of the Convention.
- ARTICLE 14
- Article 14 of the Protocol makes two changes to Article XXVI (Mutual Agreement
- Article 14 also adds a new paragraph 6 to Article XXVI (Mutual Agreement Procedure).
- ARTICLE 15
- Article 15 of the Protocol adds to the Convention a new Article XXVI A (Assistance in
- ARTICLE 16
- Article 16 of the Protocol amends Article XXVII (Exchange of Information) of the
- ARTICLE 17
- Article 17 of the Protocol amends Article XXIX (Miscellaneous Rules) of the Convention.
- Article XXII(3) of GATS specifically provides that there will be no access to GATS
- ARTICLE 18
- Article 18 of the Protocol adds a new Article XXIX A (Limitation on Benefits) to the
- ARTICLE 19
- Article 19 of the Protocol adds to the Convention a new Article XXIX B (Taxes Imposed
- Article 21 of the Protocol contains special retrospective effective date provisions for
- ARTICLE 20
- Article 20 of the Protocol does not amend the text of the Convention. It states two
- ARTICLE 21
- Article 21 of the Protocol provides the rules for the entry into force of the Protocol
- ARTICLE 1
- Article 1 of the Protocol amends paragraph 3 of Article XIII (Gains) of the Convention.
- ARTICLE 2
- ARTICLE 3
- Article 3 of the Protocol contains the rules for bringing the Protocol into force and giving
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