On September 21, 2007 the Minister of Finance, Jim Flaherty, and the United States Secretary of the Treasury, Henry M. Paulson, signed the Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”). The amendments and additions to the Treaty contained in the Protocol are significant and will have a major impact on the way in which Canada-US cross-border planning is implemented once the Protocol is ratified and effective.

type Tax Law Bulletin - September 26, 2007 - The Fifth Protocol To The Canada-US Income Tax Convention