This document is a technical explanation of the Convention between the United States and South Africa which was signed on February 17, 1997 (the "Convention"). References in this Explanation to the "U.S. Model" are to the United States Model Income Tax Convention, published on September 30, 1996. References to the "OECD Model" are to the Model Tax Convention on Income and on Capital, published by the OECD in 1992, as subsequently amended. References to the "U.N. Model" are to the United Nations Model Double Taxation Convention between Developed and Developing Countries, published in 1980. The...

Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the U.S. Treasury Department's Model Income Tax Convention published on September 30, 1996. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the "OECD Model") and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as...

This is a Technical Explanation of the Convention between the United States and the Republic of Poland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Warsaw on February 13, 2013 (the "Convention"). Negotiations 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"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic...

This is a technical explanation of the Protocol between the United States and New Zealand signed at Washington on December 1, 2008 (the "Protocol") amending the Convention and Protocol between the United States and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Wellington on July 23, 1982 (the "existing Convention"). Negotiations 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")....

Negotiations took into account the U.S. Treasury Departments current tax treaty policy and the U.S. Treasury Department=s Model Income Tax Convention published on September 20, 1996 (the A U.S. Model) between the first and second rounds of negotiations for this Convention, as well as the Model Income Tax Convention On Income and On Capital published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the AOECD Model) and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the...

This is a technical explanation of the Convention between the Government of the United States of America and the Government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Washington on November 6, 2003 (the "Convention"), and the Protocol also signed at Washington on November 6, 2003, which forms an integral part thereto (the "Protocol"). In connection with the negotiation of the Convention, the delegations of the United States and Japan developed and agreed upon an exchange of Diplomatic Notes (the "Notes"). The...

This is a technical explanation of the Convention and the Protocol between the United States and the Italian Republic signed on August 25, 1999 (the "Convention" and the "Protocol"). References are made to the Convention between the United States and Italy for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fraud or Fiscal Evasion, signed on April 17, 1984 (the "prior Convention"). The Convention replaces the prior Convention. Negotiations took into account the U.S. Treasury Department's current tax treaty policy, as reflected in the U.S. Treasury...

This is a technical explanation of the Convention between the United States and Ireland and the Protocol signed on July 28, 1997 (the "Convention" and "Protocol"). References are made to the Convention between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on September 13, 1949 (the "prior Convention"). The Convention replaces the prior Convention. In connection with the negotiation of the Convention and the Protocol, the negotiators developed and...

This is a technical explanation of the Convention between the United States and Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on February 23, 2007, and the Protocol between the United States and Bulgaria signed on the same date (the "Protocol"), as amended by the Protocol between the United States and Bulgaria signed on February 26, 2008 (collectively, the "Convention"). The Protocol is discussed below in connection with the relevant articles of the Convention. Negotiations took into account the U.S. Treasury...

This document is a technical explanation of the Convention and Protocol between the United States and Venezuela that was signed at Caracas on January 25, 1999 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, as reflected in the U.S. Treasury Department's Model Income Tax Convention of September 20, 1996 (the "U.S. Model") and its recently negotiated tax treaties, the Model Income Tax Convention on Income and on Capital, published by the OECD in 1992 and amended in 1994, 1995 and 1997 (the "OECD Model"), and recent tax treaties...