The US Treasury has not updated its Model Income Tax Convention since 2016, a document that primarily serves as a negotiating baseline for crafting tax treaties with other nations. Despite substantial changes to international tax law including the 2017 Tax Cuts and Jobs Act and the widespread adaptation of digital services taxes, the existing model is still in use, potentially complicating the work for international tax teams.
Tax professionals know the feeling. A deadline passes, you check the calendar twice, and somebody finally asks the question everyone else has been thinking: “Did we miss something?” That is roughly where U.S. treaty watchers find themselves in 2026. Treas...
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