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15226 1 (2009-12-01)

handle is hein.usccsset/usconset50036 and id is 1 raw text is: AUTHENTICATED
U.S. OVERNMENT
INFORMATION
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                  111TH CONGRESS            SEAEExEc. REPT.
                     1st Session            SENATE                 111-1



                  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 (TREATY DOC. 111-4)



                                DECEMBER 1, 2009.-Ordered to be printed


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

                                          REPORT

                                    [To accompany Treaty Doc. 111-4]
                    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 French Re-
                  public 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, as Amended by the Protocol
                  signed on December 8, 2004, signed January 13, 2009, at Paris, to-
                  gether with a related Memorandum of Understanding, signed Jan-
                  uary 13, 2009 (the Protocol) (Treaty Doc. 111-4), having consid-
                  ered the same, reports favorably thereon with one declaration and
                  one condition, 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 accom-
                  panying resolution of advice and consent.

                                           CONTENTS
                                                                           Page
                    I. P u rpose  ...........................................................................................................  2
                    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  .........................................................................................  4
                  VII. Committee Recommendation and Comments .............................................  4
                  VIII. Text of Resolution of Advice and Consent to Ratification .......................... 5
                  IX. Annex 1.- Technical Explanation  ...............................................................  9


89-119

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