Two countries form a treaty under the general principles of contract law. A fundamental aspect of contract law requires a meeting of the minds – a shared understanding of the agreed terms. Accordingly, unless expressly stated, a treaty ought to apply only to the two contracting sovereigns. But this is about tax law, tax treaties, and, more importantly, an exploitation point for statutory interpretation. States may, under certain theories of interpretation, be bound to the provisions of a tax treaty between the United States and a foreign country.