This is a technical explanation of the Convention between the United States and the other Contracting State]1 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed on date] (the "Convention"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy, and the United States Model Income Tax Convention of November 15, 2006. 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.