First impressions from the United Kingdom of the new United Kingdom-United States tax treaty

The United Kingdom and the USA signed a new income tax treaty on 24 July 2001, which will replace the 1975 treaty between the two countries. This article examines the significance of some of the more important features of the new treaty, such as the provisions relating to dividends, hybrid entities, conduit arrangements, pensions, capital gains, limitation on benefits, and treaty interpretation.