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Ex. Rept. 116-4 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                              116-4



                            PROTOCOL AMENDING TAX CONVENTION
                                       WITH LUXEMBOURG


                                    JULY 10, 2019.-Ordered to be printed


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

                                            REPORT
                                      [To accompany Treaty Doc. 111-8]
                     The Committee on Foreign Relations, to which was referred the
                   Protocol Amending the Convention between the Government of the
                   United States of America and the Government of the Grand Duchy
                   of Luxembourg for the Avoidance of Double Taxation and the Pre-
                   vention of Fiscal Evasion with Respect to Taxes on Income and
                   Capital, signed on May 20, 2009 at Luxembourg and a related
                   agreement effected by the exchange of notes also signed on May 20,
                   2009 (the Protocol) (Treaty Doc. 111-8), having considered the
                   same, reports favorably thereon with one declaration, as indicated
                   in the resolution of advice and consent, and recommends that the
                   Senate give its advice and consent to ratification thereof, as set
                   forth in this report and the accompanying 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  ...........................................................................................  2
                     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 .......................... 4
                   IX. Annex 1.- Technical Explanation  ...............................................................  5
                                             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 Luxembourg, and to bring the existing treaty with Lux-
                   embourg into conformity with current U.S. tax treaty policy. Prin-
                   cipally, the Protocol would amend the existing tax treaty with Lux-
                      89-119

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