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The New United States Model Income Tax Convention

42 Pages Posted: 22 Jun 2007 Last revised: 11 Feb 2008

Reuven S. Avi-Yonah

University of Michigan Law School

Martin B. Tittle

Law Office of Martin B. Tittle

Abstract

On 15 November 2006, the United States Treasury released its long-awaited new Model Income Tax Convention (New Model), which replaced the 1996 US Model (Old Model). This article reviews some of the major differences between the New and Old Models, as well as some of the major differences between the New Model and the current (2005) OECD Model Tax Convention. The article also discusses some new trends in US treaty policy which are not reflected in the New Model. The article concludes by evaluating the New Model in light of the emerging trend to use tax treaties not just to prevent double taxation, but also to combat double non-taxation.

Keywords: model tax treaty

JEL Classification: H25

Suggested Citation

Avi-Yonah, Reuven S. and Tittle, Martin B., The New United States Model Income Tax Convention. IBFD Bulletin for International Taxation, Vol. 61, p. 224, 2007; U of Michigan Law & Economics, Olin Working Paper No. 07-024; U of Michigan Public Law Working Paper No. 101. Available at SSRN: https://ssrn.com/abstract=995782

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Martin B. Tittle

Law Office of Martin B. Tittle ( email )

P.O. Box 1541
Ann Arbor, MI
United States
734-846-3864 (Phone)

HOME PAGE: http://www.martintittle.com

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