For Immediate Release
Office of the Press Secretary
September 13, 2004
Message to the Senate of the United States
TO THE SENATE OF THE UNITED STATES:
With a view to receiving the advice and consent of the Senate to
ratification, I transmit the Second Protocol Amending the Convention
Between the United States of America and Barbados for the Avoidance of
Double Taxation and the Prevention of Fiscal Evasion with Respect to
Taxes on Income Signed on December 31, 1984, signed at Washington on
July 14, 2004. Also enclosed for the Senate's information is an
exchange of notes with attached Understandings, which provide
clarification with respect to the application of the Convention, as
amended, in specified cases. Also transmitted for the information of
the Senate is the report of the Department of State with respect to the
Protocol.
The Protocol updates the existing Convention to bring it into close
conformity with current U.S. tax treaty policy and to ensure that the
Convention cannot be used inappropriately to secure tax reductions in
circumstances where there is no risk of double taxation. The Protocol
would modernize the Convention's anti-treaty-shopping provision. The
Protocol also updates the Convention to take account of a 1996 change
in the Internal Revenue Code relating to the tax treatment of certain
former long-term residents of the United States. The exchange of notes
with attached Understandings provides guidance to taxpayers and each
government regarding the intended interpretation of certain provisions
of the Convention, as amended.
I recommend that the Senate give early and favorable consideration
to this Protocol and give its advice and consent to ratification.
GEORGE W. BUSH
THE WHITE HOUSE,
September 13, 2004.
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