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  1. Canada–United States Enhanced Tax Information Exchange Agreement Implementation Act - S.C. 2014, c. 20, s. 99 (SCHEDULE : Agreement Between the Government of Canada and the Government of the United States of America To Improve International Tax Compliance Through Enhanced Exchange of Information Under the Convention Between Canada and the United States of America with Respect to Taxes on Income and on Capital)

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    • 1 Treatment of Reporting Canadian Financial Institutions: Each Reporting Canadian Financial Institution shall be treated as complying with, and not subject to withholding under, section 1471 of the U.S. Internal Revenue Code if Canada complies with its obligations under Articles 2 and 3 of this Agreement with respect to such Reporting Canadian Financial Institution, and the Reporting Canadian Financial Institution:

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      • d) to the extent that a Reporting Canadian Financial Institution is:

        • (1) acting as a qualified intermediary (for purposes of section 1441 of the U.S. Internal Revenue Code) that has elected to assume primary withholding responsibility under chapter 3 of subtitle A of the U.S. Internal Revenue Code,

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    • 3 Reliance on Third Party Service Providers: Each Party may allow Reporting Financial Institutions to use third party service providers to fulfill the obligations imposed on such Reporting Financial Institutions by a Party, as contemplated in this Agreement, but these obligations shall remain the responsibility of the Reporting Financial Institutions.

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