The Canada Revenue Agency (CRA) and Internal Revenue Service (IRS) recently released details on the new procedure to be followed by the Canadian and U.S. competent authorities for cases proceeding to arbitration under the Canada-U.S. tax treaty. The first wave of double taxation cases that have recourse under the procedure will become eligible for it on December 15, 2010. The newly issued details, released in the form of a memorandum of understanding (MOU) and a set of operating guidelines, offer the first comprehensive guidance to taxpayers on how the procedure will be implemented. 

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KPMG LLP, the audit, tax, and advisory firm, a Canadian limited liability partnership established under the laws of Ontario, is the Canadian member firm of KPMG International Cooperative (“KPMG International”). KPMG International’s member firms have over 140,000 professionals, including more than 7,900 partners, in 146 countries.