Press Room
 

FROM THE OFFICE OF PUBLIC AFFAIRS

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December 8, 2004
JS-2135

Deputy Treasury Secretary Samuel Bodman
Remarks at the Signing Ceremony for
Protocols to the Income Tax and Estate Tax Treaties
Between the United States and France

Thank you all for being here today.  It's my pleasure to welcome you to the Treasury Department.  I would like to extend a particular welcome to Ambassador Levitte and his colleagues from the French Embassy.

This Administration has made a strong commitment to our tax treaty program.  We are working to expand our treaty network by establishing new tax treaty relationships with countries around the world. 

Equally important to improving our tax treaty network is our work to keep existing agreements up-to-date.  We need to work together to ensure that our treaties continue to serve the purposes of eliminating double taxation and preventing fiscal evasion.  And the protocols we will sign here today provide a great example of that collaboration.  Through these protocols, we will improve two existing agreements between the United States and France – our income tax treaty and our estate tax treaty.

The tax treaty relationship between our countries goes back 65 years, making it one of our oldest such relationships.  This long-standing relationship is particularly notable because our legal and tax systems are in many ways quite different.  These protocols evidence our mutual commitment to ensuring that the differences in our two countries' systems do not create tax barriers to the cross-border activity that benefits both our economies.   

While these are highly technical agreements, they are important to the lives of the people who are affected by their provisions.  These two protocols include key provisions that will benefit individuals in both our countries -- including provisions relating to the tax treatment of retirement benefits and the application of estate taxes.   With the ageing of our populations, these types of provisions are becoming more and more important.

Another key provision in the income tax protocol addresses the treatment of cross-border investments made through partnerships and other similar forms of entity.  Because our two countries have very different approaches to the taxation of partnerships, ensuring the right results was a particular challenge.  But we worked together to address it.  This protocol includes rules needed to provide flexibility in terms of form-of-entity and to reduce the risk of double taxation for U.S. investors in France.   

Today we are improving an already strong treaty relationship between the United States and France.  These two protocols will further our goals of facilitating cross-border trade and investment to the benefit of the citizens and businesses of both our countries.  I very much appreciate the hard work of everyone involved – on both sides – in completing these agreements.  I am pleased to sign these protocols today.

 

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