This article explores the issue of the attribution of income to a person for tax treaty purposes. The article considers how the attribution of income to a person relates to various areas of current international concern and offers some thoughts on what, the article argues, is a more fundamental issue in this respect, namely, the relationship between treaty entitlement and the determination of the taxable person. Specifically, the article discusses beneficial ownership, income conduits and entity conduits, attribution under domestic law, and the relationship of domestic law with treaty entitlement. The article concludes that the attribution of income to a person is too complex an issue to be dealt with in one rule. The issue operates on several levels, each of which raises its own policy considerations and requires solutions appropriate to that level.