US Deputy Treasury Secretary, Samuel Bodman, and the French Ambassador to the
United States, Jean-David Levitte on Wednesday signed protocols amending the
US-France Income Tax and Estate Tax Treaties.
Speaking at the signing ceremony, Mr Bodman stressed the importance to the
US government of keeping its tax treaty network up to date, observing with relation
to the country's relationship in this area with France that:
"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."
He went on to add that:
"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."
The Deputy Treasury Secretary additionally explained that:
"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."