This is a technical explanation of the Convention between the Government of the United States and the Government of Iceland For the Avoidance Of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on October 23, 2007 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the Treasury Department's Model Income Tax Convention. 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. The Technical Explanation is an official guide to the Convention and an accompanying Protocol. It reflects the policies behind particular Convention and Protocol provisions, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention and Protocol. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her."