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Article XVIII A of the 1942 Convention authorizes the issuance of regulations to specify

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

circumstances under which residents of the United States temporarily performing personal services in Canada may be exempted from deduction and withholding of United States tax. This provision is omitted from the Convention as unnecessary. The Code and regulations provide sufficient authority to avoid excessive withholding of U.S. income tax. Further, paragraph 2 provides for adjustments in the amount of withholding where appropriate.

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▸Contents — U.S. Income Tax Treaty — Canada Technical Explanation - 1980

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