Elimination of Canadian Withholding Tax on Certain Cross-Border Loans

With the signing of the Fifth Protocol to the Canada-U.S. Tax Treaty on September 21, 2007, the elimination of withholding tax on interest on certain cross-border loans, as announced in the March 2007 federal Budget, is expected to come into effect as early as March 1, 2008. This article addresses the impact of these proposed changes to cross-border financings. For a more general overview of these changes, and several other key changes to the Treaty, please read the companion article, New Protocol to Canada-U.S. Tax Treaty.