Negotiations took into account the U.S. Treasury Departments current tax treaty policy and the U.S. Treasury Department=s Model Income Tax Convention published on September 20, 1996 (the A U.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. 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 A he" or A his should be read to mean A he or she or A his or her.