in-print-bilateral-benefits-0409-en

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Unformatted text preview: en their operations tend to make them interdependent.34 similar language and examples can be found in technical explanations to other us treaties.35 However, the technical explanation to the protocol does not contain any discussion or examples of complementary businesses. in addition, the technical explanation states that income may be considered to be earned in connection with or incidental to an active trade or business in Canada or the united states even if the resident that claims the benefit derives the income, directly or indirectly, through one or more persons that are residents of the other treaty country. For example, the technical explanation states that a Canadian resident can claim benefits with respect to income earned by a us operating subsidiary but derived through a wholly owned us holding company interposed between it and the us operating subsidiary. Presumably, this example refers to dividends ultimately received by the Canadian resident that were earned in connection with the active trade or business carried on by the us operating subsidiary. On July 16, 2008, following the release of the techni...
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