Today, the Organization for Economic Cooperation and Development (OECD) released a discussion draft that includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds.  As explained in the discussion draft, the “draft includes draft changes to Articles 3 [General Definitions] and 4 [Resident] of the OECD Model Tax Convention, and to the Commentary on these Articles, that will ensure that a pension fund is considered to be a resident of the State in which it is constituted for the purposes of tax treaties.”  Such changes were discussed by Working Party 1 on Tax Conventions and Related Questions, a subgroup of the OECD Committee on Fiscal Affairs in charge of the Model Tax Convention, during its February 2016 meeting. Comments on the draft should be sent by April 1.