This Convention shall not affect the tax privileges of diplomatic representatives or consular agents, in accordance with the general rules of international law or the provisions of special agreements. The Government of Canada and the Government of the United States of America, which wish to amend and supplement in some way the Convention signed in Washington on March 4, 1942, and the Protocol thereto on the Prevention of Double Taxation and the Prevention of Tax Evasion with Respect to Income Tax, have decided to conclude a supplementary convention to this effect and have appointed their respective agents: (Note – A U.S. expat can take full advantage of the treaty waivers if they reside in Canada for at least 330 days a year, which is similar to the agreement the U.S. has with other counties.) 8. Where a person resident in a Contracting State sells property in the course of a company or other organization, a restructuring, merger, division or similar transaction and the profit, profit or income related to such an assignment shall not be recognized for taxation purposes in that State if the person acquiring the immovable property so requires: The competent authority of the other Contracting State may agree, in order to avoid double taxation and under conditions satisfactory to that competent authority, to postpone until the date and in accordance with the Convention the recognition of the profit, profit or income of such property for the purposes of taxation in that other State. 4. Where, pursuant to paragraph 1, an estate, trust or other person (excluding one or more companies) is established in both Contracting States, the competent authorities of the States shall endeavour by mutual agreement to clarify the matter and to determine the nature and application of the Convention to that person. They may also consult each other on the elimination of double taxation in cases not provided for in the Convention. Canada and the United States each have very unique tax systems. However, both countries have signed a tax treaty to avoid double taxation and prevent tax evasion with respect to income tax and capital tax. The Canada-U.S. Income Tax Agreement ensures that a resident of a country is not taxed by either country on the same income in the same year.
(hereinafter “double taxation”). This is especially important when a person lives in one country and travels daily to work in the other country or temporarily moves to the other country to work for a limited period of time. 11. The competent authorities of the States Parties shall agree on the nature and effect of this Article, including the Agreement, to ensure a comparable level of assistance to each Of the States Parties. 2. The competent authority of the Contracting State to which the case has been brought shall endeavour, if the objection appears to it to be justified and if it is unable to find a satisfactory solution itself, to resolve the case by mutual agreement with the competent authority of the other Contracting State with a view to tax evasion which is not in conformity with the Agreement. Unless the provisions of Article IX (related persons) apply, any agreement concluded shall be transposed into the domestic law of the Contracting States, notwithstanding any limitation of time or any other procedure, provided that the competent authority of the other State Party has been informed of the existence of such a case within six years of the end of the fiscal year to which the case relates. . .