WithholdingGenerally, Canada requir

Withholding
Generally, Canada requires withholding of 25% on income paid to a nonresident and the US generally imposes a 30% withholding tax. The Treaty provides for reduced withholding on many types of income. Examples are:
 Interest – 0% on most types of interest payments
 Dividends – 15% unless the dividend is paid to a parent corporation in the other country that owns at least 10% of the voting shares, then the withholding rate is 5%.
 Pensions – 15%
Death Taxes
The purpose of the article of the Treaty is to coordinate the death taxes of the two countries. Without the Treaty, there would be double tax because Canadian’s death tax is an income tax and the US death tax is an estate tax (tax on assets) so barring the Treaty, there would be no way to take a foreign tax credit or otherwise eliminate double tax.
US death taxes include estate, gift and generation-skipping transfer tax. It does not include state death taxes.
The US estate tax system provides an exemption from tax on the first US$5,430,000 of net assets. That exemption is referred to as the Applicable Exclusion Amount (AEA). The Treaty provides a pro rata Applicable Exclusion Amount equal to the deceased’s US assets, divided by worldwide assets, times the AEA (US$5,430,000 per person in 2015 and indexed for inflation) and will no event be less than US$60,000.
The Treaty also provides a special Martial Credit allowance for transfers to spouses. The deceased is allowed a doubling of the amount from above, if:
 The property passing is “qualifying property.”
 Decedent must have been a resident of either Canada or the US, or a Canadian or US citizen at the time of death.
 The surviving spouse must have been a resident of either Canada or the US, or a Canadian or US citizen at the time of the decedent’s death.
 If both the decedent and the spouse were residents of the US at death, at least one of them has to be a Canadian citizen.
 Must irrevocably waive the benefits of the unlimited marital deduction.
Canada agrees to give Canadian residents that are not US citizens or green card holders a credit for US federal and state inheritance tax on US property. This credit is allowed against Canadian tax paid. The US agrees to give credit against federal estate for Canadian federal and provincial income taxes imposed at death.
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In summary, this means that if you have worldwide assets that are less than the AEA (US$5,430,000 in 2015 or US$10,860,000 for a couple), there will be no US estate tax. If however, your worldwide assets exceed the AEA, you could be subject to US nonresident estate tax.
Let’s take an easy example. You are single and your worldwide assets are equal to US$10,000,000. Included in the US$10,000,000 is a home you own in your own name in Florida that is worth US$1,000,000. You would be able to exclude US$5,430,000 times US assets over worldwide assets, or 1,000,000/10,000,000, or 10%. Ten percent of $5,430,000 is $543,000. So $543,000 would be excluded and you would owe tax on $457,000. If you were married to a Canadian, the entire amount would be excluded and there would be not tax.
Note: There are planning techniques that can be used prior to death that could prevent the house, in this example, from being included as a US asset and therefore not subject to nonresident estate tax. Also, any tax you pay in the US can be taken as a credit against your final Canadian income tax.
Note: That as long as the assets are considered US assets and the total US assets exceed $60,000, you must file a US estate tax return. The practical explanation as to why you will have to file a US estate tax return is quite obvious, you are claiming that your worldwide assets are less than the AEA; the IRS is not simply going to take your word for it, they will need you to provide substantiation and a signed return claiming the amounts to be true.
Final comment
The last thing to note is that if you are using any provision of the Treaty to alter the tax that would otherwise be owed under domestic law, you must file a return and disclose the fact you are using a provision of the Treaty to reduce your tax. As explained above in the estate tax example, just because you have no tax due, does not mean that you have no tax return due.

Hasil (Bahasa Indonesia) 1:

PemotonganUmumnya, Kanada membutuhkan pemotongan sebesar 25% pendapatan dibayarkan kepada warga dan AS umumnya membebankan pajak 30%. Perjanjian menyediakan untuk pemotongan berkurang banyak jenis pendapatan. Contoh adalah: Bunga – 0% pada kebanyakan jenis pembayaran bunga Dividen – 15% kecuali dividen yang dibayarkan kepada induk perusahaan di negara lain yang memiliki setidaknya 10% dari dividen, maka tingkat pemotongan adalah 5%. Tumpangan – 15%Kematian pajakTujuan dari artikel dari Perjanjian adalah untuk mengkoordinasikan pajak kematian yang kedua negara. Tanpa perjanjian, akan ada pajak ganda karena Kanada kematian pajak adalah pajak penghasilan dan pajak kematian US pajak (pajak pada aset) jadi kecuali perjanjian tersebut, tidak akan ada cara untuk mengambil kredit pajak asing atau sebaliknya menghilangkan pajak ganda.US kematian pajak termasuk estate, hadiah dan pajak pengalihan generasi-lompat. Tidak termasuk pajak kematian negara.Sistem pajak AS memberikan pembebasan dari pajak pada pertama AS$ 5,430,000 aset net. Pembebasan itu disebut sebagai jumlah pengecualian berlaku (AEA). Perjanjian menyediakan proporsional jumlah pengecualian berlaku sama dengan almarhum 's KAMI aset, dibagi dengan aset di seluruh dunia, kali AEA (US$ 5,430,000 per orang dalam 2015 dan diindeks inflasi) dan acara tidak akan kurang dari US$ 60, 000.Perjanjian juga menyediakan tunjangan bela diri kredit khusus untuk transfer ke pasangan. Almarhum diperbolehkan dua kali lipat dari jumlah dari atas, jika: The property passing is “qualifying property.” Decedent must have been a resident of either Canada or the US, or a Canadian or US citizen at the time of death. The surviving spouse must have been a resident of either Canada or the US, or a Canadian or US citizen at the time of the decedent’s death. If both the decedent and the spouse were residents of the US at death, at least one of them has to be a Canadian citizen. Must irrevocably waive the benefits of the unlimited marital deduction.Canada agrees to give Canadian residents that are not US citizens or green card holders a credit for US federal and state inheritance tax on US property. This credit is allowed against Canadian tax paid. The US agrees to give credit against federal estate for Canadian federal and provincial income taxes imposed at death.© Copyright Cross Border Tax & Accounting. All Rights Reserved www.cbta.netIn summary, this means that if you have worldwide assets that are less than the AEA (US$5,430,000 in 2015 or US$10,860,000 for a couple), there will be no US estate tax. If however, your worldwide assets exceed the AEA, you could be subject to US nonresident estate tax.Let’s take an easy example. You are single and your worldwide assets are equal to US$10,000,000. Included in the US$10,000,000 is a home you own in your own name in Florida that is worth US$1,000,000. You would be able to exclude US$5,430,000 times US assets over worldwide assets, or 1,000,000/10,000,000, or 10%. Ten percent of $5,430,000 is $543,000. So $543,000 would be excluded and you would owe tax on $457,000. If you were married to a Canadian, the entire amount would be excluded and there would be not tax.Note: There are planning techniques that can be used prior to death that could prevent the house, in this example, from being included as a US asset and therefore not subject to nonresident estate tax. Also, any tax you pay in the US can be taken as a credit against your final Canadian income tax.Note: That as long as the assets are considered US assets and the total US assets exceed $60,000, you must file a US estate tax return. The practical explanation as to why you will have to file a US estate tax return is quite obvious, you are claiming that your worldwide assets are less than the AEA; the IRS is not simply going to take your word for it, they will need you to provide substantiation and a signed return claiming the amounts to be true.Final commentThe last thing to note is that if you are using any provision of the Treaty to alter the tax that would otherwise be owed under domestic law, you must file a return and disclose the fact you are using a provision of the Treaty to reduce your tax. As explained above in the estate tax example, just because you have no tax due, does not mean that you have no tax return due.