In responding to a query which noted that the Canada-U.S. Treaty, unlike other Conventions, specifically referred to deferral agreements of competent authorities being entered into to avoid double taxation, and asked whether "the Canadian Competent Authority [would] be willing to enter into a deferral agreement under one of these other treaties where the profit, gain or income is exempted or excluded from taxation under the domestic laws of the residence," CRA responded negatively:
...the Canadian Competent Authority requires taxpayers seeking a deferral agreement to demonstrate that the profit, gain or income for which an agreement is being sought is only deferred - not exempted or excluded - from taxation under the domestic laws of the residence state.
More specifically, CRA noted that the conditions respecting a deferral application under the U.S. Treaty in paras. 76-85 of Information Circular 71-17R5 are "equally applicable to all requests made under the deferral provisions in any of Canada's tax treaties."