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Finance committee  Madagascar is not a signatory to this multilateral convention and, to my knowledge, has not indicated its intention to sign the treaty. As a result, the treaty with Madagascar, if ratified, would not be covered by this instrument.

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  I think we had a briefing binder that was distributed. In the news release the government issued when the notice of ways and means was tabled, the backgrounder also set out which provisions Canada proposes to opt into at the time of ratification. That would be opting into artic

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Currently, Canada has not proposed to opt into article 3. Canada has a reservation in respect of the OECD model tax convention where such a provision is also contained. It was developed, generally speaking, by OECD member countries. It extends to include situations where there ma

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  No, the provision that is in the multilateral instrument is a provision that would allow for treaty benefits in certain circumstances where a transparent entity exists. It would clarify those situations. It would also provide for benefits when that transparent entity is in a thir

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  My apologies for the confusion.

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Typically, conventions, and specifically tax conventions, have a differing entry into force and entry into effect. It would be in force in respect of Canada; however, it would have no effect on any of our tax treaties, on any transactions that taxpayers undertook, until the date

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  The United States is not a party to this agreement. While it participated in the early days of the negotiation of this instrument, towards the end of the negotiations it indicated that it did not intend to become a signatory to this convention.

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Generally, the USMCA itself would not be impacted by anything in this tax treaty. Generally speaking, the USMCA provides that, to the extent that there's a tax treaty in place, the tax treaty should apply, as opposed to the USMCA. The fact that the United States is not going to

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Canada has not deposited its instrument of ratification yet. However, 19 other signatories to the multilateral instrument have deposited their instruments of ratification. The first five deposited them in the first half of last year. The treaty itself entered into force on July 1

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Canada would deposit its ratification notice after this bill receives royal assent. The Minister of Foreign Affairs would then seek an order in council to authorize her to send a notification to the depositary in respect of Canada's ratification of the instrument. Assuming that t

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  There are no specified times within which you have to deposit your notice of ratification. Obviously the earlier the notice of ratification is deposited, the earlier the entry into force. Then the next step is the entry into effect of this instrument. Because of the way this mult

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  My apologies. I did mean September 2019.

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  Yes, I'm sorry.

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  If we were to deposit our instrument of ratification prior to September 30, 2019, then the convention would come into force at the beginning of the three months after that date. So depending on the date we do it, it would be late 2019 or January 1, 2020. As long as we get an entr

February 5th, 2019Committee meeting

Stephanie Smith

Finance committee  The bill was signed in June 2017. Following that, the government tabled this implementing bill, Bill C-82, to enact the MLI into Canadian domestic legislation. Following royal assent to this bill, Canada would be in a position to notify the depositary of this convention that it

February 5th, 2019Committee meeting

Stephanie Smith