Common Contracts

MEMORANDUM OF UNDERSTANDING BETWEEN THE COMPETENT AUTHORITIES OF CANADA AND THE UNITED STATES REGARDING THE MUTUAL AGREEMENT PROCEDURE

June 14th, 2005

• Filed
  June 14th, 2005

The Director General, International Tax Directorate, Canada Customs and Revenue Agency (CCRA), Competent Authority for Canada and the Director-International, Large and Medium Size Business (LMSB), Internal Revenue Service (IRS), Competent Authority for the United States through this Memorandum of Understanding (“MOU”) agree to establish principles and guidelines to improve the performance and efficiency of the mutual agreement procedure (“MAP”) process in accordance with the terms set forth in the Canada-United States Income Tax Convention (1980), as amended from time to time (the “Convention”).