The application of tax treaties to cases involving partnerships raises a number of complex issues. When is a partnership entitled to the benefits of a tax convention? What happens when the residence and source States apply different articles of the Convention on the basis of differences in their...

The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction...