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Treasury Official on Why U.S. Did Not Sign BEPS Multilateral Instrument

12 June 2017

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Treaty Development

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United States-OECD

While speaking at a recent conference, U.S. Treasury deputy international tax counsel, Henry Louie, explained the reasons the U.S. decided not to sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) ({News-2017-06-08/T/2- previous coverage}). According to Louie, one of the main reasons is that U.S. tax treaty policy is already consistent with most of the provisions of the BEPS MLI, including existing savings clauses, provisions for the taxation of transparent entities, limiting benefits for investors in third states, etc. Treasury also has concerns with the BEPS MLI PPT/LOB provisions and mandatory arbitration provisions, which Treasury...