[Congressional Record (Bound Edition), Volume 151 (2005), Part 16]
[Senate]
[Page 21479]
[From the U.S. Government Publishing Office, www.gpo.gov]




REMOVAL OF INJUNCTION OF SECRECY, PROTOCOL AMENDING THE TAX CONVENTION 
                 WITH FRANCE--TREATY DOCUMENT NO. 109-4

  Mr. GRASSLEY. Mr. President, as in executive session, I ask unanimous 
consent that the injunction of secrecy be removed from the following 
treaty transmitted to the Senate on September 28, 2005, by the 
President of the United States: Protocol Amending the Tax Convention 
with France (Treaty Document No. 109-4). I further ask unanimous 
consent that the treaty be considered as having been read the first 
time, that it be referred, with accompanying papers, to the Committee 
on Foreign Relations and ordered to be printed, and that the 
President's message be printed in the Record.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  The message of the President is as follows:

To the Senate of the United States:
  With a view to receiving the advice and consent of the Senate to 
ratification, I transmit herewith a Protocol Amending the Convention 
Between the Government of the United States of America and the 
Government of the French Republic for the Avoidance of Double Taxation 
and the Prevention of Fiscal Evasion with Respect to Taxes on Income 
and Capital, signed at Paris on August 31, 1994 (the ``Convention''), 
signed at Washington on December 8, 2004 (the ``Protocol''). Also 
transmitted for the information of the Senate is the report of the 
Department of State with respect to the Protocol.
  The Protocol was negotiated to address certain technical issues that 
have arisen since the Convention entered into force. The Protocol was 
concluded in recognition of the importance of U.S. economic relations 
with France.
  The Protocol clarifies the treatment of investments made in France by 
U.S. investors through partnerships located in the United States, 
France, or third countries. It also modifies the provisions of the 
treaty dealing with pensions and pension contributions in order to 
achieve parity given the two countries' fundamentally different pension 
systems. The Protocol makes other changes to the Convention to reflect 
more closely current U.S. tax treaty policy.
  I recommend that the Senate give early and favorable consideration to 
this Protocol and that the Senate give its advice and consent to 
ratification.
                                                      George W. Bush.  
The White House, September 28, 2005.

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