A newly revised U.S. Model Income Tax Convention – the baseline text the U.S. Treasury Department uses when negotiating tax treaties – was issued in mid-February, shortly before the annual International Fiscal Association (IFA) USA Conference convened in Miami.
Fenwick & West tax partner Larissa Neumann – a panelist at the conference's session on treaty developments – discussed the revised U.S. Model Treaty (also known as "the 2016 Model"). According to an account in Tax Notes, Neumann said the special tax regime provision will make treaties more dynamic, but also less reliable.
Neumann – who appears as a rising star in Euromoney's "World's Leading Tax Advisers" and was named to the Silicon Valley Business Journal's 40 Under 40 in 2015 – also said the "provision is now much more narrowly tailored than the version put out in May of 2015."
Fenwick partner James Fuller – one of the world’s top 25 tax advisers, and one of the world’s leading transfer pricing advisers, according to Euromoney – was also a featured speaker at the conference, chairing a panel on U.S. and OECD transfer pricing developments.
IFA is the leading non-governmental, international organization dealing with tax matters. The annual conference held by the USA Branch, IFA's largest, helps tax experts stay up to date on developments in the field.
The full article is available through the Tax Notes website (subscription required).