Last year the U.S. Treasury department announced proposed changes to the U.S. Model Income Tax Treaty, which is the model text used by American officials when they negotiate tax treaties with other countries. According to a press release issued by Treasury in May 2015, “The revisions to the U.S. Model text are intended to ensure that the United States is able to maintain the balance of benefits negotiated under its treaty network as the tax laws of our treaty partners change over time, and to deny treaty benefits to companies that change their tax residence in an inversion transaction.”
USCIB and other business groups have expressed concern that the treaty provisions tilt too far in the direction of denying inappropriate claims of treaty benefits. Although Treasury recently narrowed some of the anti-tax evasion provisions to be more palatable to the U.S. business community, tax practitioners say that the model’s reception will be uncertain, especially among America’s treaty partners.
Speaking to Bloomber BNA, USCIB Vice President for Tax Carol Doran Klein noted that the treaty is complex and will be difficult to negotiate with other nations.
“It’s really, really complicated, which is not surprising,” Klein said. “I do think that some of the novel provisions have been modified, which is better. But it’s going to be really difficult to get this negotiated and also to apply it.”
Uncertainty also remains as to how the proposed changes to the U.S. model tax treaty might impact the OECD’s work on Base-Erosion and Profit-Shifting (BEPS).
USCIB sent a letter to the U.S. Treasury on September 14 expressing concern with proposed U.S. model tax treaty changes, which in part attempt to prevent double non-taxation of income between tax treaty partners. While acknowledging that the treaty provisions address legitimate concerns, USCIB said that the draft provisions “tilt too far in their attempt to prevent inappropriate claims of treaty benefits.”
President Obama signed the Trade Facilitation and Trade Enforcement Act, commonly referred to as Customs Reauthorization, into law on February 25,
Supporting six million American jobs and hosting two thirds of the global middle class, the Asia-Pacific region is of great interest to the business community, as global companies are eager to tap the region’s growing markets. The Asia-Pacific Economic Cooperation (APEC) forum – the most influential economic dialogue in the region – continues to be a priority for USCIB members, as it is key to accelerating regional economic integration and promoting balanced, sustainable growth.
One of the most contentious issues during the United Nations COP21 climate negotiations was the push by NGOs and some countries to frame intellectual property (IP) rights as a barrier to environmental goals. USCIB and other business groups made a strong case for IP frameworks, arguing that innovation is crucial for developing solutions to the world’s climate challenges, and thanks to their efforts IP was not mentioned in the final climate treaty agreed to in Paris last year.

As in years past, January 1st is the time that many Americans make New Year’s resolutions. Often those are associated with a pledge to live a healthier lifestyle. One can experience the result of this undertaking in overcrowded gyms, jam-packed yoga classes and in the media with advice on how to keep those resolutions. Health and wellness is top-of-mind for many of us, and especially with policymakers. While each of us may be experiencing different challenges to achieve our own optimum well-being, there is no dispute that health is important for all.

Chaired by ICC Secretary General John Danilovich, the event also featured Adebayo Shittu, minister of communications, Nigeria, Nermine El Saadany, under secretary for international relations division, Ministry of Communications and Information Technology, Egypt and ICC BASIS members Jimson Olufuye, chairman, Africa ICT Alliance (AfICTA).