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The US Treasury Department's draft Model Income Tax Convention,
published in 1981 (the 1981 Model), was withdrawn as the official
US Model in 1992. This monograph contains an article-by-article,
paragraph-by-paragraph analysis of the new 1996 US Model Tax
Convention. Each paragraph is compared with any corresponding
provisions in the 1981 US Tax convention and the 1995 OECD Model
Convention. In addition, the technical explanation accompanying the
new 1996 US Model is discussed and analyzed. The 1996 US Model not
only offers insight into the Treasury's negotiating position with
respect to future tax treaties, but also provides insight into
Treasury's interpretation of existing treaties that employ language
similar to that in the new US Model.
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