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Article X does not apply to dividends paid by a company which is not a resident of either

U.S. Income Tax Treaty — Canada Technical Explanation - 1980 · 2026-10-03 edition · updated 2026-10-04 · United States

Contracting State. Such dividends, if they are income of a resident of one of the Contracting States, are subject to tax as provided in Article XXII (Other Income).

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▸Contents — U.S. Income Tax Treaty — Canada Technical Explanation - 1980
U.S. Income Tax Treaty — Canada Technical Explanation - 1980

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