12.3.1 U.S. Taxation of Outbound Royalty Payments 12.3.1[a] Definition of RoyaltiesThe Code generally defines the term “royalty” by enumerating the kinds of property...
4.5.2 [a] New Tie-Breaker RuleIf a particular company is a resident of both Canada and the United States, the language of new Article IV(3)[a] provides that where a company...