The U.S. Model Income Tax Convention: a comparison with the OECD's

This thesis compares two model tax conventions: the United States model income tax convention (U.S. Model) and the OECD model tax convention on income and on capital (OECD Model). Nowadays, more than 3,500 income tax treaties exist worldwide. Most of these international agreements are based on the OECD Model. However, some countries prefer to use their own models. The U.S. is one of them. Despite joining the OECD in 1961, the United States has maintained its own model, which represents its main reference document when negotiating income tax treaties with other countries. The thesis aims to identify the main differences between these two models that have remained consistent throughout revisions and updates. It analyses how the U.S. Model has evolved over time and provides a detailed comparison with the OECD Model, on an article-by-article basis. The findings show that while the U.S. Model follows the OECD Model in terms of structure and treaty terminology, it contains provisions that reflect U.S. own priorities and the distinctive features of the U.S. tax system.