On May 20, 2015, the U.S. Treasury Department released proposed
changes to the U.S. model tax treaty, which has not been updated
since 2006.
The Treasury Department has departed from its usual process for
revising the U.S. model tax treaty by publishing drafts of certain
of the more meaningful proposed revisions and inviting comments
from practitioners. In addition, another unusual aspect of the
Treasury Department's handling of these revisions is that
previous revisions to the U.S. model tax treaty have generally
reflected developments originating in existing tax treaty
negotiations; in this case, however, the Treasury Department is
designing new provisions on a prospective basis. These departures
from the Treasury Department's historical process reflect a
fast-moving policy debate currently spearheaded by the OECD, which
has been developing a series of reports and proposals under its
base erosion and profit shifting (BEPS) initiative involving the
United States
