Message to the Senate Transmitting the Protocol Amending the France-United States Taxation Convention

To the Senate of the United States:

I transmit herewith for the advice and consent of the Senate to ratification a Protocol Amending the Convention Between the United States of America and the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Estates, Inheritances, and Gifts, signed at Washington on November 24, 1978 (the "Convention"), signed at Washington on December 8, 2004 (the "Protocol"). Also transmitted for the information of the Senate is the report of the Department of State with respect to the Protocol.

The Protocol provides a pro rata unified credit to the estate of a French domiciliary for purposes of computing U.S. estate tax. It allows a limited U.S. "marital deduction" for certain estates if the surviving spouse is not a U.S. citizen. In addition, the Protocol expands the United States jurisdiction to tax its citizens and certain former citizens and long-term residents and makes other changes to the treaty to reflect more closely current U.S. tax-treaty policy.

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

GEORGE W. BUSH

The White House, November 3, 2005.