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Ex. Rept. 116-3 1 (2019-07-10)

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U.S. GOVERNMENT
INFORMATION
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                   116TH CONGRESS              SN                  I EXEC. REPT.
                      1st Session JSENATE                               116-3



                                    PROTOCOL AMENDING THE
                                  TAX CONVENTION WITH JAPAN


                                     JULY 10, 2019.-Ordered to be printed


                          Mr. RISCH, from the Committee on Foreign Relations,
                                        submitted the following

                                             REPORT

                                      [To accompany Treaty Doc. 114-1]
                     The Committee on Foreign Relations, to which was referred the
                   Protocol Amending the Convention between the United States of
                   America and the Government of Japan for the Avoidance of Double
                   Taxation and the Prevention of Fiscal Evasion with Respect to
                   Taxes on Income and a related agreement entered into by an ex-
                   change of notes (together with the proposed Protocol), both signed
                   on January 24, 2013, at Washington, together with correcting notes
                   exchanged March 9 and March 29, 2013 (Treaty Doc. 114-1), hav-
                   ing considered the same, reports favorably thereon with a declara-
                   tion and conditions, as indicated in the resolution of advice and
                   consent, and recommends that the Senate give its advice and con-
                   sent to ratification thereof, as set forth in this report and the ac-
                   companying resolution of advice and consent.
                                              CONTENTS
                                                                                Page
                      I. P u rp o se  ...........................................................................................................  1
                      II.  B ack grou n d  ...................................................................................................  2
                    III. M ajor  P rovision s  ...........................................................................................  2
                    IV . E n try  Into  F orce  ...........................................................................................  3
                    V . Im plem enting  Legislation  .............................................................................  3
                    V I. C om m ittee  A ction  .........................................................................................  3
                    V II.  Com m ittee  Com m ents  ...................................................................................  3
                    VIII. Text of Resolution of Advice and Consent to Ratification .......................... 5
                    IX. Annex 1.- Technical Explanation  ...............................................................  8
                                              I. PURPOSE
                     The purpose of the Protocol, along with the underlying treaty, is
                   to promote and facilitate trade and investment between the United
                   States and Japan. Many of the provisions in the proposed Protocol
                   are intended to bring the existing Convention in closer conformity
                   with the 2006 U.S. Model, accounting for particular aspects of Jap-
                      89-119

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