Guide to the UK / US Tax Treaty

This detailed commentary on the UK/US Double Tax Treaty covers the purpose of treaties, background to the convention, a general discussion on treaty trends and the OECD. The publication consists of a detailed analysis of each article, including: the text of the relevant article in full; an overview outlining the need for the article and its broad effect indicating any significant differences from the OECD or US model treaties; a discussion of the key terms highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles; envisaged difficulties in application or contentious issues including areas that the treaty does not address or adequately provide for; reference to relevant commentaries from US or UK authorities and a general explanation of any available planning opportunities using the article e.g. standard structures or treaty uses.