The Minister of Finance announced today that a protocol has been signed to amend the treaty with Barbados. This is a good sign as it has been under negotiation for many years.
A couple of highlights are the clearer definition of resident and article XXX now protects Canada’s tax base more clearly with the stipulation that “Nothing in this Agreement shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a company, partnership, trust, or other entity, in which that resident has an interest”.