The Treasury Department released a statement on 7 June 2007 commenting on the Authorized OECD Approach (AOA) for the attribution of profits to permanent establishments. The Treasury Department stated that although it had incorporated the AOA into a few recent US tax treaties, including  Japan andthe United Kingdom, and in thebew US Midel Treaty, it would not apply the AOA to most existing US treaties. The Treasury Department stated that it disagreed with the "symmetry" requirement set forth in para. 44 of the draft Revised Commentary on Art. 7 of the OECD Model Tax Convention, and further that it believed...