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Unformatted text preview: ents been made to the owner of the resident of the recipient contracting state directly. For the most part, these tests remain virtually identical to those under the pre-existing treaty, except that they now also apply to us residents that seek treaty benefits from Canada.
a us or Canadian person that is unable to qualify for treaty benefits under any of the preceding tests may apply to the Canadian or us competent authorities under article xxix a(6) for a determination that it nevertheless should be granted treaty benefits. ImPlIC aTIoNs for C aNadIaN Ta XPayers
For the first time, a Canadian resident that makes payments to a us resident now bears the responsibility for determining whether the recipient of the payments is a qualifying person or meets the other tests under the LOb article. This determination becomes important, for example, when a company is considering whether it is eligible for reduced tax rates on dividend payments, interest payments, and royalty 10 see New York City bar, Committee on Taxation of...
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