[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.