加拿大对加美税收协定中的“常设机构”一词作出最新解释。 　　一、某美国公司总经理是加拿大居民，该公司只在加开有一个基金帐户，以便与某些联属企业进行结算，此外与加无任何联系。加税收署认为，只要该美国公司总经理到过加拿大，根据加—美所得税协定第Ⅳ条第 3段的规 Canada gives the latest explanation of the term “permanent establishment” in the Canada-Canada tax treaty. The general manager of a U.S. company is a resident of Canada. The company only has a fund account in Canada to settle with certain affiliates, and there is no connection with Canada. The taxation office believes that as long as the general manager of the U.S. company has been to Canada, according to the regulation of Article IV, paragraph 3, of the Canada-US Income Tax Agreement