ARTICLE I
U.S. Income Tax Treaty — Canada Income Tax Treaty and Protocols - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States
Paragraph 5 of Article XVIII (Pensions and Annuities) of the Convention shall be deleted and replaced by the following: “5. Benefits under the social security legislation in a Contracting State paid to a resident of the other Contracting State shall be taxable as follows:
(a) Such benefits shall be taxable only in that other State; (b) Notwithstanding the provisions of subparagraph (a), one-half of the total amount of any such benefit paid in a taxable year shall be exempt from taxation in that other State.”
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