A comparative analysis of the 1981 and 1996 U.S. Model Income Tax Treaties

Article Abstract:

The increased importance of the global economy and philosophical differences between nations has contributed to US tax policy changes reflected in changes made to the 1981 model income tax treaty. A revised model income tax treaty was issued by the US Treasury Dept. in 1996. Notable issues to which the changes are addressed include relation to domestic tax law, types of taxes, residence, permanent establishment, dividends, and other definitional and source-related issues.

Tax Treaties, International Affairs, International aspects, international

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A forward look at the United States-Canada tax relationship

Article Abstract:

Canada and the United States are achieving common ground on some tax issues, one being the source-country taxation of pensions to which Article 6 of the United States-Canada Income Tax Treaty speaks. Based on the treaty's expansion of the categories of Canadian income taxes covered, a greater integration of the two countries' tax systems appears likely and this will include nonincome and income taxes. Both countries are also pushing forward in administrative law areas.

Interpretation and construction, Canada, Laws, regulations and rules, Foreign source income taxation

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U.S. views on current European parent-subsidiary tax developments

Article Abstract:

Changes in European tax laws will need to be carefully planned for by US holding companies seeking to maximize tax savings on the dividends of foreign operations. Reorganization of companies is facilitated by recent EC directives regarding mergers, share exchange, subsidiary liquidations, corporate divisions and business transfers. Applicable US and EC tax laws are presented with examples.

International business enterprises, Multinational corporations

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