International Tax IssuesAnswered

Canada Article IV(7) — when does the anti-hybrid rule block my treaty claim through a US LLC?

JC
justin_ca_0bc8new member
May 15, 2026 412 views 1 answer
canada treatyarticle IV(7)anti-hybridfifth protocoltreaty mismatch

I'm Canadian. I read that Canada Article IV(6) helps disregarded-entity owners claim the US-Canada treaty, but there's a related Article IV(7) that can block it. When does IV(7) kick in and how do I avoid the trap?

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