[Weekly Compilation of Presidential Documents Volume 40, Number 38 (Monday, September 20, 2004)]
[Pages 1980-1981]
[Online from the Government Publishing Office, www.gpo.gov]

<R04>
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 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.

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