Treasury Issues Proposed Revisions to the U.S. Model Tax Treaty

Treasury Issues Proposed Revisions to the U.S. Model Tax Treaty:  Treasury has issued proposed revisions to the U.S. Model Income Tax Convention (U.S. Model treaty), addressing various areas.  The U.S. Model treaty was last updated in 2006.  According to the Department of Treasury the proposed revisions are intended to address “special tax regimes,” which provide low tax rates for income such as royalties and interest, to reduce the tax benefits from corporate inversions, and to address BEPS by preventing residents of third-countries from inappropriately obtaining the benefits of a bilateral tax treaty.  Treasury is requesting comments on the proposed revisions.  At a DC Bar lunch today, Treasury officials indicated that a more complete version of the new U.S. Model treaty would eventually be released.