U.S.–Canada Tax Treaty Resources

Official treaty text, IRS treaty directory, Publication 901, and the Canada–U.S. Totalization Agreement — curated by Tax Master Inc. CPAs.

1980Treaty signed (amended 5×)

30+Articles covering key income types

0%Withholding on pension income (Art. XVIII)

5%Reduced dividend rate for >10% ownership

Important: Treaty Claims Require Disclosure

Claiming treaty benefits without filing required disclosure forms (Form 8833, W-8BEN) can result in penalties and disallowed treaty positions. Tax Master Inc. reviews treaty eligibility before you file.

Key Treaty Articles — Quick Reference

Article IV

Tax Residence

Determines which country taxes you as a resident — tiebreaker rules for dual residents

Article VII

Business Profits

Permanent establishment rules — when a Canadian business owes U.S. tax

Article X

Dividends

5% withholding (≥10% ownership), 15% otherwise — reduced from 30% default

Article XI

Interest

0% withholding on most cross-border interest payments between related parties

Article XII

Royalties

0–10% withholding on royalties depending on type — copyright, patent, know-how

Article XIII

Capital Gains

Rules for taxing gains on real property, business assets, and securities

Article XV

Employment Income

183-day rule — income from employment is taxable only in country of work

Article XVIII

Pensions & RRSPs

RRSP, RPP, CPP, OAS — how Canadian retirement plans are treated for U.S. tax

Article XXIV

Elimination of Double Tax

Foreign tax credit mechanism to prevent the same income being taxed twice

Article XXIX-A

Limitation on Benefits

Anti-treaty shopping rules — ensures only eligible residents receive treaty benefits

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Official Treaty Documents & Directories

Primary source documents for the U.S.–Canada Income Tax Convention and related social security agreement.

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U.S. Treasury — U.S.–Canada Tax Treaty Text (as amended) Full text of the 1980 Convention and all five protocols. The authoritative legal source for treaty positions.

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IRS — U.S. Tax Treaties A to Z IRS directory of all U.S. income tax treaties. Find Canada, Australia, and other country treaty summaries and technical explanations.

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IRS Publication 901 — U.S. Tax Treaties IRS plain-language summary of treaty benefits by country. Includes withholding rates, pension treatment, and student exemptions.

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SSA — U.S.–Canada Totalization Agreement Social Security coordination agreement. Prevents dual CPP/Social Security contributions for cross-border workers.

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Let Us Review Your Treaty Position Before You File

Tax Master Inc. applies the U.S.–Canada Tax Treaty correctly — W-8BEN, Form 8833, RRSP elections, branch profits reduction. Loudoun County, VA.

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