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Ex. Rept. 114-3 1 (2016-02-08)

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                   114TH CONGRESS               SEAEExEc. REPT.
                      2d Session                SENATE                   114-3



                                 TAX CONVENTION WITH POLAND



                                   FEBRUARY 8, 2016.-Ordered to be printed


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

                                             REPORT

                                       [To accompany Treaty Doc. 113-5]
                     The Committee on Foreign Relations, to which was referred the
                   Convention between the United States of America and the Republic
                   of Poland For the Avoidance of Double Taxation and the Prevention
                   of Fiscal Evasion with Respect to Taxes on Income (the Conven-
                   tion) (Treaty Doc. 113-5), having considered the same, reports fa-
                   vorably thereon with one declaration, as indicated in the resolution
                   of advice and consent, and recommends that the Senate give its ad-
                   vice and consent to ratification thereof, as set forth in this report
                   and the accompanying resolution of advice and consent.

                                               CONTENTS
                                                                                 Page
                      I. P u rpose  ...........................................................................................................  1
                      II.  B ackground  ....................................................................................................  2
                      III.  M ajor  Provisions  ............................................................................................  2
                      IV .  E ntry  Into  Force  ...........................................................................................  3
                      V. Im plem enting  Legislation  .............................................................................  3
                      V I.  Com m ittee  A ction  .........................................................................................  3
                    VII. Com m ittee  Com m ents  ...................................................................................  3
                    VIII. Text of Resolution of Advice and Consent to Ratification ..........................  5
                    IX. Annex 1.- Technical Explanation  ...............................................................  6
                                              I. PURPOSE
                     The purpose of the Convention is to promote and facilitate trade
                   and investment between the United States and Poland. The pro-
                   posed Convention replaces the existing convention, signed in 1974,
                   and would bring United States-Poland tax treaty relations into
                   closer conformity with current U.S. tax treaty policies. The Conven-
                   tion contains rigorous protections designed to protect against trea-
                   ty shopping, which is the inappropriate use of a tax treaty by
                   third-country residents, that are not contained in the existing trea-
                   ty. While the proposed Convention generally follows the 2006 U.S.
                       59-119

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