David Rosenbloom Discusses U.S. Uses New Model Treaty Language in Luxembourg Protocol with Tax Notes
H. David Rosenbloom spoke with Tax Notes concerning the U.S. Treasury's announcement on June 22 that it is negotiating a protocol to amend the Luxembourg-U.S. tax treaty in order to block tax planning strategies that result in double non-taxation. To view the complete article, please visit Tax Notes' website (subscription required).
Excerpt taken from the article "U.S. Uses New Model Treaty Language in Luxembourg Protocol" by Alexander Lewis for Tax Notes.
This is not just an issue with respect to U.S.-source income, but applies to foreign-source income as well, according to H. David Rosenbloom of Caplin & Drysdale. Rosenbloom questioned why Treasury decided to use a protocol to deal with the issue instead of addressing it with a competent authority agreement under the existing treaty. "Since we have had no action on any U.S. treaty since November of 2011, and are not likely to see any action until [Sen.] Rand Paul changes his mind or the rest of the Senate grows a backbone, I fail to understand the choice of the protocol route," Rosenbloom said.