For Immediate Release
Office of the Press Secretary
November 4, 2005
Message to the Senate of the United States
TO THE SENATE OF THE UNITED STATES:
I transmit herewith for the advice and consent of the Senate to
ratification a Protocol Amending the Convention Between the United
States of America and the French Republic for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on
Estates, Inheritances, and Gifts, signed at Washington on November 24,
1978 (the "Convention"), signed at Washington on December 8, 2004 (the
"Protocol"). Also transmitted for the information of the Senate is the
report of the Department of State with respect to the Protocol.
The Protocol provides a pro rata unified credit to the estate of a
French domiciliary for purposes of computing U.S. estate tax. It allows
a limited U.S. "marital deduction" for certain estates if the surviving
spouse is not a U.S. citizen. In addition, the Protocol expands the
United States jurisdiction to tax its citizens and certain former
citizens and long-term residents and makes other changes to the treaty
to reflect more closely current U.S. tax-treaty policy.
I recommend that the Senate give early and favorable consideration to
the Protocol and give its advice and consent to ratification.
GEORGE W. BUSH
THE WHITE HOUSE,
November 3, 2005.
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