UNITED STATES MODEL TECHNICAL — U.S. Income Tax Treaty

This is a technical explanation of the Convention between the United States and [the other Contracting State]1 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed on [date] (the “Convention”).

Negotiations took into account the U.S. Department of the Treasury’s current tax treaty policy, and the United States Model Income Tax Convention of November 15, 2006. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the “OECD Model”), and recent tax treaties concluded by both countries.

The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. References in the Technical Explanation to “he” or “his” should be read to mean “he or she” or “his and her.”