Beschrijving

The Model is drawn from a number of sources. Instrumental in its development was the U.S. Treasury Department’s draft Model Income Tax Convention, published on June 16, 1981 (”the 1981 Model”) and withdrawn as an official U.S. Model on July 17, 1992, the Model Double Taxation Convention on Income and Capital, and its Commentaries, published by the OECD, as updated in 1995 (”the OECD Model”), existing U.S. income tax treaties, recent U.S. negotiating experience, current U.S. tax laws and policies and comments received from tax practitioners and other interested parties.