United States-France Convention on Income and Property Taxes Message to the Senate Transmitting a Protocol to the Convention.

To the Senate of the United States:

I transmit herewith, for Senate advice and consent to ratification, a Protocol to the Convention between the United States of America and the French Republic with Respect to Taxes on Income and Property of July 28, 1967, as amended by the Protocol of October 12, 1970. The Protocol, together with a related exchange of notes, was signed at Washington on November 24, 1978. For the information of the Senate, I also transmit the related exchange of notes and the report of the Department of State with respect to the Protocol.

The Protocol breaks new ground by providing for the first time that the country of residence (France) and the country of citizenship (United States) share the responsibility to avoid double taxation of expatriate U.S. citizens.

Early ratification of the Protocol is essential as a new French law which takes effect on January 1, 1979, may otherwise subject U.S. citizens living in France to double taxation. The Protocol provides for retroactive effect, upon entry into force, to January 1, 1979.

The accompanying exchange of notes clarifies the treatment by France of certain income and expenses of U.S. citizens resident in France. It also points out certain issues of continuing concern for which no current solution could be found.

I recommend that the Senate give early and favorable consideration to this Protocol and advise and consent to its ratification.

JIMMY CARTER

The White House,

February 9, 1979.