Finance committee  Thank you.

Finance committee  Yes, potentially it would. If a Taiwanese shareholder of a Canadian company.... If there were such a case and if it received dividends, interest, or royalties from that company, then lower withholding tax rates would apply, unlike in a case where there was no arrangement in place

Finance committee  Well, we see a value generally in having tax treaties in place because of the certainty that they provide, as we discussed earlier. In these particular cases, it's helpful for firms to know that they have this lower withholding tax, and other taxes, in place to give them certaint

Finance committee  That's a very large question. We do cleave to our view expressed earlier that tax treaties are beneficial. I don't mean to qualify that at all. However, there is a concern sometimes, and this is the point that you're seeking to lead to, that there can be tax minimization by multi

Finance committee  We're speaking of individuals rather than corporations?

Finance committee  For individuals, very generally it's where you have the closest connections. There are “deemed” rules where if you spend so many days in Canada you may be treated as a resident, or if you're a member of the diplomatic corps you may be deemed to be a Canadian resident. Apart from

Finance committee  You can start with that, and then countries may challenge you on it. I'll ask my colleague to speak about the special rules, the specific rules we have in both of these treaties.

Finance committee  I don't think there are any issues unique to either of these agreements, or arrangement. It is possible for somebody, first of all, to make a claim to be resident in two or more countries. That's probably not something they would generally be inclined to do. It's possible for two

Finance committee  Very basically, it is as I said in my opening remarks, which is that if it were delayed until next year for implementation, then the effective start of the treaty will be the calendar year following. If it actually can be passed this year, and the notices to the other jurisdictio

Finance committee  Well, the bill was—

Finance committee  It's a fair question, first of all, to be sure. The point is that Taiwan was signed earlier in the year. Israel was only signed in September. The bill was tabled, I think, November 1st, and that's where we ended up. I don't have any other explanation than that.

Finance committee  It is important to note that this is not a trade agreement, per se. It's a rule governing the application of taxes in both jurisdictions. As Ms. Smith acknowledged a moment or two ago, the level of trade between countries matters, but it's actually more of an investment focus.

Finance committee  We could verify this, but we don't believe so. Stephanie has talked about the anti-avoidance provisions that apply for our withholding tax. Those are not novel; we have those in other treaties.

Finance committee  We think so, yes. As Ms. Smith explained, with respect to Taiwan, we thought it was necessary to have a provision to essentially provide that Taiwan is to be treated as a country for the sake of making sure that our domestic rules in relation to tax treaties all apply. Having don

Finance committee  Please don't treat me as being irreverent, but an arrangement is not an agreement. In finding another term that did not imply a contractual agreement, the word “arrangement” was landed on. Beyond saying that it's something less than an agreement, I don't know that I can offer any