Law360, New York ( July 9, 2015, 10:35 AM EDT) -- The U.S. Model Income Tax Treaty generally represents the United States' opening position in treaty negotiations. As a result, any changes to such treaty need to be carefully analyzed to determine whether they potentially can impact existing cross-border structures. On May 20, 2015, the U.S. Department of the Treasury released five proposed amendments to the U.S. model treaty, which, if adopted in their current form, undoubtedly will have a major impact on many inbound structures. In general, the proposals are intended to ameliorate the problem of so-called "stateless income" as well as influence the Organization for Economic Cooperation and Development's work on the "base erosion and profit shifting" (BEPS) initiative....
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