[Congressional Record Volume 149, Number 176 (Tuesday, December 9, 2003)]
[Senate]
[Pages S16158-S16159]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




           TAXATION CONVENTION WITH JAPAN--TREATY DOC. 108-14

To the Senate of the United States:
  I transmit herewith, for Senate advice and consent to ratification, 
the Convention between the Government of the United States of America 
and the Government of Japan for the Avoidance of Double Taxation and 
the Prevention of Fiscal Evasion with respect

[[Page S16159]]

to Taxes on Income, signed at Washington on November 6, 2003, together 
with a Protocol and an exchange of notes (the ``Convention''). I also 
transmit, for the information of the Senate, the report of the 
Department of State concerning the Convention.
  This Convention would replace the Convention between the United 
States of America and Japan for the Avoidance of Double Taxation and 
the Prevention of Fiscal Evasion with respect to Taxes on Income, 
signed at Tokyo on March 8, 1971.
  This Convention, which is similar to tax treaties between the United 
States and other developed nations, provides rules specifying the 
circumstances under which income that arises in one of the countries 
and is derived by residents of the other country may be taxed by the 
country in which income arises, providing for maximum source-country 
withholding tax rates that may be applied to various types of income 
and providing for protection from double taxation of income. The 
proposed Convention also provides rules designed to ensure that the 
benefits of the Convention are not available to persons that are 
engaged in treaty shopping. Also included in the proposed Convention 
are rules necessary for administering the Convention.
  I recommend that the Senate give early and favorable consideration to 
this Convention, and that the Senate give its advice and consent to the 
ratification of the Convention.
                                                      George W. Bush.  
The White House, December 9, 2003.

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