This is a Technical Explanation of the Convention between the Government of the United States and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed on February 4, 2010 (the "Convention") as well as an amending Protocol signed the same day (the "Protocol"). Negotiations on the Convention took into account the U.S. Treasury Department's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. On the date of signing of the Convention and the Protocol, the United States and Chile also exchanged diplomatic Notes (the "2010 Exchange of Notes") relating to various provisions of the Convention and the Protocol. The United States and Chile also exchanged diplomatic Notes on February 25, 2011 (the "2011 Exchange of Notes") and on February 10 and 21, 2012 (the "2012 Exchange of Notes"). The 2010, 2011, and 2012 Exchanges of Notes constitute an integral part of the overall agreement between the United States and Chile. The Technical Explanation is an official guide to the Convention, Protocol, and Exchanges of Notes. It reflects the policies behind particular Convention provisions, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention, Protocol, and Exchanges of Notes. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her." References to the "Code" are to the Internal Revenue Code of 1986, as amended.