This is a technical explanation of the Convention between the United States and Ireland and the Protocol signed on July 28, 1997 (the "Convention" and "Protocol"). References are made to the Convention between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on September 13, 1949 (the "prior Convention"). The Convention replaces the prior Convention. In connection with the negotiation of the Convention and the Protocol, the negotiators developed and agreed upon an exchange of diplomatic notes. The notes constitute an agreement between the two governments which shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and the tax authorities of both Contracting States in interpreting the relevant provisions of the Convention. Negotiations took into account the U.S. Treasury Department's current tax treaty policy, the Model Income Tax Convention on Income and on Capital, published by the OECD in 1992 and amended in 1994 and 1995 (the "OECD Model") and recent tax treaties concluded by both countries. References to the "U.S. Model" refer to the U.S. Treasury Department's Model Income Tax Convention of September 20, 1996, which was issued after negotiation of the Convention was substantially completed, although prior drafts of the U.S. Model were available and taken into account in the course of negotiations.