April 18, 1984
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 Protocols of October 12, 1970, and November
24, 1978. The present Protocol was signed at Paris on January 17, 1984. I also transmit the report
of the Department of State on the Protocol.
The principal reason for further amending the Convention is the recently enacted French wealth
tax which could adversely affect Americans living in France. The Protocol exempts from this tax
foreign assets owned by United States citizens temporarily resident in France. The Protocol also
provides an exemption from tax at source on interest, and it includes rules for limiting the benefits
of the Convention to residents of the United States or France.
I recommend that the Senate give early and favorable consideration to the Protocol and give
advice and consent to its ratification.
Ronald Reagan
The White House,
April 18, 1984.