    [Public Papers of the Presidents of the United States: George W. Bush (2005, Book II)]
    [September 28, 2005]
    [Page 1495]
    [From the U.S. Government Publishing Office www.gpo.gov]

    Message to the Senate Transmitting the Protocol Amending the France-
    United States Taxation Convention
    September 28, 2005

    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.