Department of the Treasury Technical Explanation of the Convention Between the United States of America and the Rebublic of Estonia For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income

This is a technical explanation of the Convention between the United States and the Republic of Estonia signed on January 15, 1998 (the AConvention@). 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 20, 1996 (the AU.S. Model@) between the first and second rounds of negotiations for this Convention, as well as the Model Income Tax Convention On Income and On Capital published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the AOECD Model@) and recent tax treaties concluded by both countries.