    [Public Papers of the Presidents of the United States: George W. Bush (2004, Book II)]
    [September 13, 2004]
    [Pages 2046-2047]
    [From the U.S. Government Publishing Office www.gpo.gov]

    Message to the Senate Transmitting the Second Protocol Amending the
    Barbados-United States Taxation Convention
    September 13, 2004

    To the Senate of the United States:
        With a view to receiving the advice and consent of the Senate to
    ratification, I transmit the Second Protocol Amending the Convention
    Between the United States of America and Barbados for the Avoidance of
    Double Taxation and the Prevention of Fiscal Evasion with Respect to
    Taxes on Income Signed on December 31, 1984, signed at Washington on
    July 14, 2004. Also enclosed for the Senate's information is an exchange
    of notes with attached Understandings, which provide clarification with
    respect to the application of the Convention, as amended, in specified
    cases. Also transmitted for the information of the Senate is the report
    of the Department of State with respect to the Protocol.
        The Protocol updates the existing Convention to bring it into close
    conformity with current U.S. tax treaty policy and to ensure that the
    Convention cannot be used inappropriately to secure tax reductions in
    circumstances where there is no risk of

    [[Page 2047]]

    double taxation. The Protocol would modernize the Convention's anti-
    treaty-shopping provision. The Protocol also updates the Convention to
    take account of a 1996 change in the Internal Revenue Code relating to
    the tax treatment of certain former long-term residents of the United
    States. The exchange of notes with attached Understandings provides
    guidance to taxpayers and each government regarding the intended
    interpretation of certain provisions of the Convention, as amended.
        I recommend that the Senate give early and favorable consideration
    to this Protocol and give its advice and consent to ratification.

                                                              George W. Bush

     The White House,

     September 13, 2004.