The 1996 United States Model Income Tax Convention: Analysis, Commentary and Comparison

The US Treasury Department's draft Model Income Tax Convention, published in 1981 (the 1981 Model), was withdrawn as the official US Model in 1992. This monograph contains an article-by-article, paragraph-by-paragraph analysis of the new 1996 US Model Tax Convention. Each paragraph is compared with any corresponding provisions in the 1981 US Tax convention and the 1995 OECD Model Convention. In addition, the technical explanation accompanying the new 1996 US Model is discussed and analyzed. The 1996 US Model not only offers insight into the Treasury's negotiating position with respect to future tax treaties, but also provides insight into Treasury's interpretation of existing treaties that employ language similar to that in the new US Model.