Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the U.S. Treasury Department's Model Income Tax Convention published on September 30, 1996. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the "OECD Model") and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her."