Q. Is it hard for countries to collect tax debts from residents of other counrries? A. I'ts the "Revenue Rule". In tax law, absent special enforcement treaties, sovereign countries do not enforce the revenue laws of other countries (the "revenue rule"). https://t.co/N4ZX4LJPSvpic.twitter.com/idRq77GvYv
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 1, 2019
Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens https://t.co/DMdIlHqMU7
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 6, 2018
Introduction – The Purpose of this post
This is an addition to “The Little Red Tax Treaty Book“. I was recently asked the following question:
I heard that the Canada U.S. Tax Treaty means that the Canada Revenue Agency will not help the United States collect a U.S. tax debt on a Canadian citizen, provided that the person was a Canadian citizen at the time the U.S. tax debt arose. But, what if the person was NOT a Canadian citizen when the U.S. tax debt arose? Will the Canada Revenue Agency help the United States collect U.S. tax debt? My answer to the question:
On September 21, 2007 Canada and the United States signed the 5th Protocol to the Canada U.S. tax treaty (first entered into in 1980). As a result of the 5th protocol, Paragraph 8 (a) of Article XXVIA now reads: Continue reading →
5 US Tax Treaties where "treaty partner" agrees 2 assist US 2 collect taxes on residents of treaty partner country https://t.co/sxElCTAvlr
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 19, 2016
The above tweet references the comment I left on an article titled: ”
Why is the IRS Collecting Taxes for Denmark?
which appeared at the “Procedurally Speaking” blog.
The article is about the “assistance in collection” provision which is found in 5 U.S. Tax Treaties (which include: Canada, Denmark, Sweden, France and the Netherlands). I am particularly interested in this because of a recent post at the Isaac Brock Society.
This post discusses the “assistance in collection” provision found in Article XXVI A of the Canada U.S. Tax Treaty. The full test of this article is: Continue reading →