Message to the Senate Transmitting the United States-Austria Convention on Taxation and Fiscal Evasion

To the Senate of the United States:

I transmit herewith, for Senate advice and consent to ratification, the Convention between the United States of America and the Republic of Austria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Estates, Inheritances, Gifts, and Generation-skipping Transfers, signed at Vienna on June 21, 1982.

The Convention is the first of its kind to be negotiated between the United States and Austria. It will apply, in the United States, to the Federal estate tax, the Federal gift tax and the Federal tax on Generation-skipping transfers and, in Austria, to the inheritance and gift tax.

A principal feature of the Convention is that the country of the transferor's domicile may tax transfers of estates and gifts and generation-skipping transfers on a worldwide basis, provided that it relieves the tax on specified types of property taxable on a situs basis.

I recommend that the Senate give early and favorable consideration to the Convention and give its advice and consent to ratification.

RONALD REAGAN

The White House,

August 10, 1982.