Overview
Tax Notes quoted Steptoe Chair Phil West in an article titled "News Analysis: What to Look for in the US Model Tax Treaty." The article, published November 30, discusses the upcoming release of the full US model treaty expected by the end of the year.
Mr. West says the two proposed changes raise some technical issues, but fundamentally, they are "memorializing a policy that has driven the negotiation of US treaties for a long time." Mr. West further explains that Treasury has viewed US treaties as premised on the assumption that they are intended to relieve double taxation, and if there is no double taxation, treaty benefits are less justified or not justified at all.
The full article can be read at Tax Notes (subscription required).
