The United States uses the U.S. Model Income Tax Convention as a starting point for treaty negotiations, and European countries and trading partners employ the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention. The United Nations tax committee has also produced a UN Model Tax Convention.

• Compare the U.S. model, OECD model, and the UN model treaties and give your opinion as to which model reduces barriers to international trade and investment by decreasing tax barriers to the international flow of goods and services.

• Defend the use of the U.S. model as opposed to the OECD or UN models by the United States. Provide an example to support your defense.