Document Type

Editorial

Publication Date

2023

Abstract

In 1945, the US negotiated a tax treaty with the UK.1 This treaty was based on the London model, which was the last contribution of the League of Nations to international tax. Since it was a treaty between the two most important economies in the world, it precipitated the post-war rise in tax treaty negotiations. It also was similar to the first OECD model of 1963. In general, with a few exceptions (citizenship-based taxation, residence of corporations, limitation on benefits) the US models of 1981, 1996, 2006 and 2016 closely resemble the OECD model. This is not surprising given the close US involvement in OECD from its inception.

Comments

Reprinted from (name of publication), (volume no.), (issue number), (date of publication), (page range), with permission of Kluwer Law International.

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