in-print-bilateral-benefits-0409-en

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Unformatted text preview: richard E. andersen and Peter H. blessing, Analysis of United States Income Tax Treaties (New York: research institute of america) (electronic resource), at paragraph 22.01(2)(c)(i)(2). i nternational tax planning n 95 commentary.26 This situation implies that a similar interpretation should be applied to the affirmatively worded “directly or indirectly” test in article xxix a(4)(a) of the Canada-us treaty. in other words, the implication is that it is sufficient if taxpayers look up the chain of ownership until they find a group of indirect shareholders that meets the requirement of this article. This issue is further discussed below in the section entitled “Derivative benefits Test.” However, the technical explanation also confirms that if 50 percent or more of the aggregate vote and value of a company that is resident in Canada or the united states are owned by a company described in article xxix a(2)(c), no further analysis of ownership of the public company’s shares is required for...
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