- 36 -
misconstrues the Treasury's interpretation. We are not persuaded
that the language set forth in the Technical Explanation of
Article VII, paragraph (7), see supra p. 31, was intended to
interpret Article VII as preserving the right to the use of all
of the domestic attribution rules. In this context, the
Technical Explanation's use of the word "paragraph" takes on a
significant meaning. The word "paragraph" in the Technical
Explanation's discussion of Article VII, paragraph (7) signals
that under paragraph 7 of Article VII, domestic rules of
attribution may remain viable. It does not necessarily follow
that all domestic rules remain so under the rest of Article VII,
particularly Article VII, paragraph (2). To adopt respondent's
interpretation would require us to substitute the word "article"
for "paragraph" and would render the limit imposed by the
separate-entity principle meaningless. By way of contrast, our
interpretation of the Technical Explanation, as it relates to
Article VII, paragraph (7), gives effect to the word "paragraph"
without modification but still preserves the rest of Article VII.
In a similar vein, we decline to infer an implicit
acceptance of attribution rules like section 842(b), on the part
of Canada, from the fact that the Technical Explanation does not
mention any conflict between the Canadian Convention and section
819(a). As we discuss below, see infra pp. 42-47, there is a
superficial similarity between prior section 819(a) and section
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