US Model Tax Convention: Proposed RevisionsBy Robert Robillard - 16 July 2015
This blogpost originally appeared on rbrt.ca.
The US Department of the Treasury has recently released its proposed revisions to its Model Tax Convention.
These changes are worth the read since they show the US hand on various BEPS-related issues relevant to actions #2, 4, 5, 6, and 7, among others.
Here are the 2015 proposed revisions to the US Model Tax Convention:
- Proposed Treaty Rule Addressing So-Called “Exempt Permanent Establishments”
- Proposed Treasury Rules Addressing Payment by “Expatriated Entities”
- Proposed Treaty Rules Addressing “Special Tax Regimes”
- Proposed Limitation on Benefits Article
- Proposed Article Addressing Subsequent Changes in Law
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