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Unformatted text preview: eptember 21, 2007. Canada ratified the protocol on December 14, 2007, when bill s-2 (an act To amend the Canada-united states Tax Convention act, 1984, sC 2007, c. 32) received royal assent. The us ratification process requires the us president to sign the protocol or an instrument of ratification. On september 23, 2008, the us senate approved the protocol by unanimous consent. On December 15, 2008, the protocol entered into force. On this date, Canada and the united states notified each other in writing through diplomatic channels that their respective procedures had been satisfied. 4 The Canada revenue agency (Cra) has attempted to apply gaar to combat perceived treaty-shopping abuses without success. see Canada v. MIL (Investments) SA, 2007 FCa 236, and Prévost Car Inc. v. The Queen, 2008 TCC 231. The decision of the Tax Court in Prévost Car is being appealed to the Federal Court of appeal. 5 united states, Treasury Department, Technical Explanation of the Protocol Done at Chelsea on september 21, 2007, amending the income Tax Convention between the united states of america and Canada (herein referred to as “the technical explanation”). 88 n c anadian tax journal / revue...
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This note was uploaded on 11/03/2013 for the course ACCOUNTING 346 taught by Professor William during the Fall '12 term at DeVry Chicago.

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