[Public Papers of the Presidents of the United States: George W. Bush (2008, Book I)]
[March 13, 2008]
[Page 371]
[From the U.S. Government Publishing Office www.gpo.gov]



Message to the Senate Transmitting the Protocol Amending the Canada-
United States Taxation Convention
March 13, 2008

To the Senate of the United States:
    I transmit herewith, for Senate advice and consent to ratification, 
the Protocol Amending the Convention Between the United States of 
America and Canada with Respect to Taxes on Income and on Capital done 
at Washington on September 26, 1980, as Amended by the Protocols done on 
June 14, 1983, March 28, 1984, March 17, 1995, and July 29, 1997, signed 
on September 21, 2007, at Chelsea (the ``proposed Protocol''). The 
proposed Protocol would amend the existing income tax Convention between 
the United States and Canada that was concluded in 1980, as amended by 
prior protocols (the ``existing Treaty''). Also transmitted for the 
information of the Senate is the report of the Department of State with 
respect to the proposed Protocol.
    The proposed Protocol would eliminate withholding taxes on cross-
border interest payments. In addition, the proposed Protocol would 
coordinate the tax treatment of contributions to, and other benefits of, 
pension funds for cross-border workers. The proposed Protocol also 
includes provisions related to the taxation of permanent establishments, 
so-called dual-resident corporations, income derived through certain 
entities that are considered fiscally transparent, and former U.S. 
citizens and long-term residents. The proposed Protocol further 
strengthens the existing Treaty's provisions that prevent the Treaty's 
inappropriate use by third-country residents. The proposed Protocol also 
provides for mandatory resolution of certain cases before the competent 
authorities.
    I recommend that the Senate give early and favorable consideration 
to the proposed Protocol and give its advice and consent to 
ratification.

                                                          George W. Bush

 The White House,

 March 13, 2008.

Note: This message was released by the Office of the Press Secretary on 
March 14.