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A detailed commentary on the new UK/US Double Tax Treaty. This new publication covers the purpose of treaties, background to the new convention, a general discussion on treaty trends and the OECD. The publication is structured as an article-by-article analysis. For each article there will be included: the text of the relevant article in full an overview outlining the need for the article and its broad effect and indicating any significant differences from the OECD or US model treaties and why these have been adopted a discussion of the key terms highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles envisaged difficulties in application or contentious issues including areas that the treaty does not address or adequately provide for, and reference to relevant commentaries from US or UK authorities a general explanation of any available planning opportunities using the article e.g. standard structures or treaty uses.
Reprint of ISBN: 9780754517238