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Unformatted text preview: titled to the benefits of the treaty, a person must, among other things, be a resident of Canada or the united states within the meaning of the treaty, and
n satisfy the requirements of the LOb article.9
n 6 Canada, Department of Finance, “Canada supports u.s. Technical Explanation of the Fifth Protocol to the Canada-united states income Tax Convention,” Release no. 2008-052, July 10, 2008. 7 “Canada revenue agency round Table” in Report of Proceedings of the Sixtieth Tax Conference, 2008 Conference report (Toronto: Canadian Tax Foundation) (forthcoming) (herein referred to as “the 2008 round table”). 8 united states, Department of the Treasury, united states Model income Tax Convention of November 15, 2006 (herein referred to as “the us model convention”). 9 The taxpayer must also be the beneficial owner of the income for which the treaty benefits are sought. i nternational tax planning n 89 The purpose of the LOb article is to prevent treaty shopping by imposing conditions that assess whether a taxpayer that claims benefit...
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