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Unformatted text preview: fiscale canadienne ( 2009) vol. 5 7 , n o 1 these questions (and others) relating to the protocol’s application. although helpful in some areas, the technical explanation does not address all questions. Canada’s minister of finance announced that Canada reviewed the us document and agrees that it “accurately reflects understandings reached in the course of negotiations with respect to the interpretation and application of the various provisions in the Protocol.”6 These comments constitute the first Canadian official endorsement of a technical explanation prepared by the united states that indicates that both countries provided their views on the application of the protocol.
During the Canada revenue agency (Cra) round table at the 2008 annual conference of the Canadian Tax Foundation,7 the Cra confirmed its intention to interpret the LOb article in a manner consistent with its object and purpose (the prevention of treaty shopping). Where limited guidance is provided, the Cra indicated...
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