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ISSUES IN INTERNATIONAL TAXATION N.6 – THE APPLICATION OF ~ THE APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS I. INTRODUCTION I.1 Background 1. In 1993, the Committee formed a Working Group to study the application of the Model Tax Convention to partnerships, trusts, and other non-corporate entities. This first report by the Working Group, which the Committee adopted on 20 January 1999 .

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