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


© 2007 Reuven S. Avi-Yonah and Martin B. Tittle. Originally published in 61 Bull. Intl. Taxn. 6, pp. 224-234, Journals IBFD. Bulletin for International Taxation is available online at Reproduced with permission.