06 June 2016

The New US Model Treaty Is Out! (BNA)

James Tobin, a partner with EY's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the release of the new US Model Treaty (the Model).

According to the article, the United States has 57 comprehensive income tax treaties in effect covering 66 countries. The United Kingdom, the Netherlands, and Switzerland all have well over 100 and even Canada has over 90. The author notes that given the increasing tax controversy environment fueled by BEPS, it's more important than ever to increase our treaty network to ensure access to potentially effective mutual dispute resolution. So, a new Model should have been the first step in an open reach-out to the world to increase our treaty network. However, according to the author, it seems like quite the opposite tone and impression is created.

The article, published in the May 13, 2016, edition of Tax Management International Journal, is attached below.

———————————————
ATTACHMENT

Full text of the article

Document ID: 2016-0973