Model Tax Treaty Eases Fears With Binding Arbitration

Law360, New York (February 26, 2016, 6:35 PM EST) -- In its update to the model U.S. tax treaty, the U.S. Department of the Treasury has included a provision for mandatory binding arbitration of international tax disputes, a move experts say should mollify multinationals' fears of double taxation in an era of increased compliance burdens.

In the preamble to the model tax treaty, released Feb. 17, the Treasury Department said changes to the treaty provisions were made with an eye toward eliminating double taxation while at the same time discouraging practices that allow companies to park income in low- or no-tax jurisdictions.

The model U.S. income tax convention is the starting...

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