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

To the Senate of the United States:

I transmit herewith, for Senate advice and consent to ratification, the Convention between the Government of the United States of America and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the Convention), together with a related exchange of notes, signed at Dacca on October 6, 1980.

The Convention, in general, follows the pattern of the United States model income tax convention, with a few departures from the model to accommodate Bangladesh's status as a developing country.

The Convention differs in one major respect from other recent United States tax treaties, including those with developing countries. In most of these treaties a source country exemption is provided for shipping and aircraft operating income. The convention with Bangladesh, however, provides exemption for aircraft income only; shipping income is taxable under the internal laws of the two Contracting States.

The exchange of notes sets out certain understandings between the two governments.

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

JIMMY CARTER

The White House,

December 2, 1980.