The new United States Model Income Tax Convention

On 15 November 2006, the United States Treasury released its long-awaited new Model Income Tax Convention, which replaced the 1996 US Model. This article reviews some of the major differences between the new and old US Models, as well as some of the major differences between the new US 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 US Model. The article concludes by evaluating the new US Model in light of the emerging trend to use tax treaties not only to prevent double taxation, but also to combat double non-taxation.