While the Fifth Protocol to the 1980 tax treaty between Canada and the U.S. entered into force on 15 December 2008 and was generally effective in respect of taxes withheld at source on 1 February 2009 (and in respect of other taxes for taxation years beginning after 31 December 2008), the extension of the provision providing for a 5% dividend withholding tax rate where the beneficial owner is a company that holds at least 10% of the voting stock of the company paying the dividends became applicable to beneficial owners that are fiscally transparent entities as from 1 January 2010.
