Effect of the U.S.-Canada Treaty Protocol on the Taxation of Real Property Holding Corporations

The Journal of Real Estate Taxation

Marc Gerson reviews the U.S. and Canadian taxation of real property holding corporations and summarizes how the U.S.-Canada Treaty Protocol resolves an issue raised by proposed Canadian legislation regarding the treatment of such corporations. As a result of the Protocol, Gerson notes "each country has the exclusive right to tax its residents on capital gains realized on shares of real property holding corporations not resident in the other country." 

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