Sincometaxtreaty specialreports2008vol49no6tax notes

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Unformatted text preview: . For taxes withheld at source, the LOb applies to amounts paid or credited on or after February 1, 2009 (the first day of the second month that begins after the protocol’s entry into force). For other taxes, the LOb is effective for taxable years beginning after 2008 (the calendar year in which the protocol entered into force). 15 income Tax act, rsC 1985, c. 1 (5th supp.), as amended (herein referred to as “the act”). unless otherwise stated, statutory references in this article are to the act and regulations made under it. 16 Canada revenue agency, Information Circular 76-12r5, “applicable rate of Part xiii Tax on amounts Paid or Credited to Persons in Countries with Which Canada Has a Tax Convention,” at paragraph 4, states that a payer can accept the name and address of the payee as that of the beneficial owner unless there is reasonable cause to suspect that the payee is not the beneficial owner. in doubtful cases, the payer should obtain a certificate from the payee. 17 During the international Fiscal association (Canadian branch) tax seminar, May 12, 2008 (herein re...
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