ARTICLE 6. NONDISCRIMINATION — U.S. Income Tax Treaty

The proposed Convention bans discrimination by one State against the na tionals of the other State or of a permanent establishment of nationals or cor porations of the other State. Thus, for example, a national of Trinidad and Tobago who is a resident of the United States and who otherwise meets the re nuirements specified in section 911 of the Internal Revenue Code would under this Article of the proposed Convention be eligible for the benefits of section 911 although such national is not a citizen of the United States.

This Article provides, however, that a State may accord special treatment to its own residents on the basis of civil status or family responsibility. This Article also provides that Trinidad and Tobago is not prohibited from imposing a branch profits tax in accordance with paragraph (5) of Article 12 (Dividends) and the

United States from imposing a comparable tax burden on the income of a per manent establishment maintained by residents of Trinidad and Tobago in the United States.

The ban on discrimination extends to all taxes without regard to subject mat ter nd whether imposed at the national, State, or local level.

This Article is substantially similar to the nondiscrimination Article of the AEOD Model Convention except that the Model includes a provislon concerning

Stateless persons which has been omitted from the proposed Convention.