This article was originally published in Tax Notes International, April 20, 2009
This article examines certain provisions of the current Korea-U.S. Income tax treaty and suggests possible amendments based on the 2006 U.S. model treaty. It also examines additional provisions that might be added to the new treaty to prevent abusive transactions and to encourage mutual exchange of information. The article is not intended to provide a comprehensive analysis of all possible amendments to the current treaty, but rather to encourage Korea and the United States to negotiate, and perhaps to serve as a platform for the initial consideration of amendments.
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This article is designed to give general information on the developments covered, not to serve as legal advice related to specific situations or as a legal opinion. Counsel should be consulted for legal advice.
