By Cris Best ( August 18, 2026, 2:55 PM EDT) -- In the case of Northcut v. The King, 2026 TCC 136 (Northcut), an appeal under the Tax Court of Canada’s informal procedure, the amount in dispute was less than $25,000 for each taxation year. Nonetheless, it is a complicated and interesting decision analyzing the intersection of Canadian and United States law, the Canada-U.S. tax treaty including Article XVIII:1 and Article XXV the non-discrimination clause, the Mutual Agreement Procedure (MAP) and the Canadian and U.S. taxation of pension income....