Canada — Related agreement (exchange of notes) 2 (signed 2024-02-15)

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ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES
OF AMERICA AND THE COMPETENT AUTHORITY OF CANADA TO UPDATE ANNEX
II OF THE AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED STATES OF
AMERICA AND THE GOVERNMENT OF CANADA TO IMPROVE INTERNATIONAL
TAX COMPLIANCE THROUGH ENHANCED EXCHANGE OF INFORMATION UNDER
THE CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND CANADA
WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
Annex II of the Agreement Between the Government of the United States of America and the
Government of Canada to Improve International Tax Compliance through Enhanced Exchange of Information under the Convention Between the United States of America and Canada with Respect to Taxes on Income and on Capital, signed on February 5, 2014 (the “IGA”) provides:
“This Annex may be modified by a mutual written decision entered into between the Competent
Authorities of Canada and the United States: (1) to include additional Entities, accounts, and products that present a low risk of being used by U.S. Persons to evade U.S. tax and that have similar characteristics to the Entities, accounts, and products identified in this Annex as of the date of signature of the Agreement….” The Competent Authority of the United States of America and the Competent Authority of Canada (the “Competent Authorities”) have reached the following arrangement (the “Arrangement”). Terms used in this Arrangement that are not defined herein have the same meanings as in the IGA.
The Competent Authorities intend to update Annex II of the IGA by adding new subsection “M” to Section IV (Accounts Excluded from Financial Accounts) of Annex II of the IGA to include an additional account that is treated as excluded from the definition of Financial Account, and therefore not treated as a U.S. Reportable Account under the IGA.
“M. Tax-Free First Home Savings Account (FHSA) – as defined under subsection 146.6(1) of the Income Tax Act.” For the Competent Authority of For the Competent Authority of the United States of America: Canada:
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Holly O. Paz
U.S. Competent Authority
Internal Revenue Service
February 1, 2024____
Date
____
Place
Tracy Annett
Director General, Legislative Policy
Directorate, Legislative Policy and
Regulatory Affairs Branch, Canada Revenue
Agency
December 27, 2023____
Date
Place
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