This is a technical explanation of the Convention between the United States and the Republic of Estonia signed on January 15, 1998. Paragraph 1 of Article 1 provides that the Convention applies to residents of the United States or Estonia except where the terms of the Convention provide otherwise. Under Article 4 (Resident) a person is generally treated as a resident of a Contracting State if that person is, under the laws of that State, liable to tax therein by reason of his domicile or other similar criteria. If, however, a person is considered a resident of both Contracting States, Article...

This is a technical explanation of the Protocol signed at Copenhagen on May 2, 2006 (the "Protocol"), amending the Convention between the United States of America and the Government of Denmark for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Washington on August 19, 1999 (the "Convention"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and Treasury's Model Income Tax Convention, published on September 20, 1996 (the "U.S. Model"). Negotiations also took into account the Model...

This is a Technical Explanation of the Convention between the Government of the United States and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed on February 4, 2010 (the "Convention") as well as an amending Protocol signed the same day (the "Protocol"). Negotiations on the Convention took into account the U.S. Treasury Department's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model")....

This is a Technical Explanation of the Protocol signed at Chelsea on September 21, 2007 (the "Protocol"), amending the Convention between the United States of America and Canada with Respect to Taxes on Income and on Capital done at Washington on September 26, 1980, as amended by the Protocols done on June 14, 1983, March 28, 1994, March 17, 1995, and July 29, 1997 (the "existing Convention"). The existing Convention as modified by the Protocol shall be referred to as the "Convention." Negotiation of the Protocol took into account the U.S. Treasury Department's current tax treaty policy and...

This is a technical explanation of the Convention between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Brussels on November 27, 2006 (the "Convention"), and the Protocol also signed at Brussels on November 27, 2006, which forms an integral part thereto (the "Protocol"). The Protocol is discussed below in connection with relevant provisions of the Convention. References are made to the Convention between the Government of the United...

This is a technical explanation of the Convention between the United States and Bangladesh signed at Dhaka on September 26, 2004(the "Convention"). Negotiations with respect to the Protocol took into account the U.S. Department of the Treasury's current tax treaty policy and Treasury's Model Income Tax Convention published September 20, 1996 (the "U.S. Model"). Negotiations also took into account the Model Income Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development (the "OECD Model"), the United Nations Model Double Taxation...

This is a technical explanation of the Protocol between the United States and Australia, signed on September 27, 2001, (the "Protocol") amending the Convention between the United States of America and Australia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on August 6, 1982 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, the Treasury Department's Model Income Tax Convention (the "U.S. Model"), published on September 20, 1996, and the Australian Model Tax Convention....

This is a technical explanation of the Protocol signed at Washington on September 30, 2005 (the "Protocol"), amending the Convention between the United States of America and the Government of Sweden for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Washington on September 1, 1994 (the "Convention"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and Treasury's Model Income Tax Convention, published on September 20, 1996 (the "U.S. Model"). Negotiations also took into account the...

This is a Technical Explanation of the Convention between the Government of the United States of America and the Government of the Democratic Socialist Republic of Sri Lanka for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Signed at Colombo March 14, 1985 (the "Convention"). The Convention was amended by a Protocol signed on September 20, 2002 (the "Protocol"), which was accompanied by an explanatory Exchange of Notes (the "Notes"). Negotiations with respect to the Protocol took into account the U.S. Treasury Department's current tax...

This is a Technical Explanation of the Protocol signed at Washington on January 14, 2013, the related Memorandum of Understanding signed the same day, and a subsequent Exchange of Notes dated July 23, 2013 (hereinafter the "Protocol," "Memorandum of Understanding" and "Exchange of Notes" respectively), amending the Convention between the United States of America and the Kingdom of Spain for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Madrid on February 22, 1990 (hereinafter the "existing Convention") and the Protocol, which...