[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.