Understanding the applicable provisions of the Canada-US income tax treaty, other applicable US income tax treaties, and the ability to take advantage of favorable provisions under particular taxpayers’ facts and circumstances is critical to successful management of one’s tax exposure, both in Canada and the United States. Anytime a business or an individual cross the border or engage in business operations or performance of services in the United States, including generating US source income, the taxpayer must review the US domestic tax law provisions and the applicable provisions of the Canada-US income tax treaty to make sure that no over withholding occurred and that the most optimal treaty relief has been granted.
Qualifying for the benefits of the Canada-US income tax treaty is no easy feat. More importantly, one needs to make a determination and support it with the applicable facts and documents.
How Can We Help !
Alexey Manasuev has substantial experience in the treaty area and has been providing his clients with practical solutions to their problems. Whether it involves a determination of one’s residency status for US federal income tax purposes or under the Canada-US income tax treaty tie-breaker provisions, or it involves a determination of qualification for treaty benefits, resolution of double taxation under the Mutual Agreement Procedure article of the Canada-US income tax treaty, or determination of whether a US permanent establishment was created, Alexey is ready to help and can do so by addressing the clients’ objectives, aligning tax result with such objectives, and by proactively looking for an opportunity to find a practical and working solution for clients’ most pertinent matters.