On Thursday, December 10, 2009, KPMG presented a webcast discussion that highlighted the new Limitation on Benefits (LOB) provisions in the treaty, focusing on the definition of qualifying persons who are eligible for full treaty benefits and the application of the active trade or business test. Also discussed was the application of the new hybrid entity rules and their impact on Canada-US structures.
The webcast featured senior International and US Corporate Tax professionals from KPMG, who shared their insights with the Canadian tax director community for the benefit of their businesses.
For further information about this topic, please read "Canada-US Tax Treaty's New LOB Rule Takes Aim at Tready Shopping" from TaxNewsFlash – Canada 2009-24 (August 5, 2009) and "Canada-US Tax Treaty Protocol – United States Kicks Off Ratification Process [PDF 172KB]" from TaxNewsFlash – Canada 2008-21 (July 11, 2008).
If you were unable to join the webcast, an archived version of it and a copy of the presentation are now available for access at any time. To access the webcast replay and a copy of the presentation, click here.
Please note that you need to register to view the webcast replay and to download the presentation.
For further information on upcoming KPMG Tax webcasts click here [PDF 95KB].