CANADA-INCOME TAXATION-DECEMBER 30, 1936 Convention between the United States of America and Canada concerning income taxation. Signed at Washington, December 30, 1936; ratifica- tion advised by the Senate, August 6, 1937; ratified by the President, August 13, 1937; ratified by Canada, August 11, 1937; ratifications exchanged at Washington, August 1S, 1937; proclaimed, August 16, 1937. BY THE PRESIDENT OF THE UNITED STATES OF AMERICA. A PROCLAMATION. WHEREAS a reciprocal convention between the United States of America and Canada concerning rates of income tax imposed upon non-resident individuals and corporations was concluded and signed by their respective Plenipotentiaries at Washington, on the thirtieth day of December, one thousand nine hundred and thirty-six, a true copy of which reciprocal convention is word for word as follows: The Government of the United States of America and the Govern- ment of Canada, being desirous of concluding a reciprocal convention concerning rates of income tax imposed upon non-resident individ- uals and corporations, have agreed as follows: ARTICLE I The High Contracting Parties mutually agree that the income taxation imposed in the two States shall be subject to the following reciprocal provisions: (a) The rate of income tax imposed by one of the Contracting States, in respect of income derived from sources therein, upon individuals residing in the other State, who are not engaged in trade or business in the taxing State and have no office or place of business therein, shall not exceed five per centum for each taxable year, so long as an equivalent or lower rate of income taxation is imposed by the other State upon individuals residing in the former State who are not engaged in trade or business in such other State and do not have an office or place of business therein. (b) The rate of income tax imposed by one of the Contracting States, in respect of dividends derived from sources therein, upon non-resident foreign corporations organized under the laws of the other State, which are not engaged in trade or business in the taxing State and have no office or place of business therein, shall not exceed five per centum for each taxable year, so long as an equivalent or lower rate of income taxation on dividends is imposed by the other State upon corporations organized under the laws of the former State which are not engaged in trade or business in such other State and do not have an office or place of business therein. December 30, 1936 [T. S. No. 9201 Convention with Canada concerning in- come taxation. Preamble. Purposes declared. Reciprocal provi- sions. 1399
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