Real property. Article II 1. Real property situated in Canada shall be exempt from the appli- cation of the taxes imposed by the United States of America. 2. Real property situated in the United States of America shall be exempt from the application of the taxes imposed by Canada. 3. The question whether rights relating to or secured by real property are to be considered as real property for the purposes of this Conven- tion shall be determined in accordance with the laws of the contract- ing State imposing the tax. Article III 1. Shares in a corporation organized in or under the laws of the United States of America, of any of the states or territories of the United States of America, or of the District of Columbia, shall be deemed to be property situated within the United States of America. 2. Shares in a corporation organized in or under the laws of Canada, or of any of the provinces or territories of Canada, shall be deemed to be property situated within Canada. 3. This Article shall not be construed as limiting the liability of the estate of any person not domiciled in Canada or of any citizen of the United States of America, under the estate tax laws of the United States of America. Article IV 1. The situs of property shall be determined in accordance with the laws of the contracting State imposing the tax, except as otherwise provided in this Convention. 2. Allowances for debts shall be determined in accordance with the laws of the contracting State imposing the tax. 3. Domicile shall be determined in accordance with the laws of the contracting State imposing the tax. Shares of stock. Determination of situs, domicile, etc. Article V ' Estates of deceased persons. 1. In the case of a decedent who at the time of his death was a citizen of, or domiciled in, the United States of America, the United States of America may include in the gross estate any property (other than real property) situated in Canada as though this Convention had not come into effect. 2. In the case of a decedent (other than a citizen of the United States of America) who at the time of his death was domiciled in Canada, the United States of America shall, in imposing the taxes to which this Convention relates: (a) take into account only property situated in the United States of America; and (b) allow as an exemption an amount which bears the same ratio to the personal exemption allowed in the case of a decedent who was at the time of his death a citizen of, or domiciled in, the United States of America as the value of the property of TREATIES [59 STAT.
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