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Under Article XVIII, pensions and annuities from Canadian sources paid to U.S. residents are subject to tax by Canada, but the tax is limited to 15% of the gross amount (if a periodic pen-sion payment) or of the taxable amount (if an annuity). Canadian pensions and annuities paid to U.S. residents may be taxed by the United States, but the amount of any pension included in income for U.S. tax purposes may not be more than the amount that would be included in income in Canada if the recipient were a Cana-dian resident.Pensions. A pension includes any payment under a pension or other retirement arrange-ment, Armed Forces retirement pay, war veter-ans pensions and allowances, and payments under a sickness, accident, or disability plan. It includes pensions paid by private employers and the government for services rendered.
Pensions also include payments from indi-vidual retirement arrangements (IRAs) in the United States, registered retirement savings plans (RRSPs) and registered retirement in-come funds (RRIFs) in Canada.
Pensions do not include social security ben-efits.
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