EXCELLENCY. I have the honor to refer to the Convention between the Government of the United States of America and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, together with a related Protocol, signed at Washington on March 4, 1994 ('Taxation Convention") and the General Agreement on Trade in Services ("GATS"). The Government of the United States is a Party to the GATS, annexed to the Agreement Establishing the World Trade Organization, done at Marrakesh April 15, 1994. The Government of Ukraine is not yet a party to the GATS. The United States and Ukraine have, however, considered the relationship between the Taxation Convention and the GATS in the event that the GATS applies between them, particularly with regard to the Consultation provision in Article XXII of the GATS and the Most-Favored-Nation and National Treatment provisions in Articles II and XVII of the GATS. In addition, the United States and Ukraine have considered the relationship between the Taxation Convention and other agreements that apply between them and that have provisions concerning national treatment or most-favored-nation treatment. To address these issues, I have the honor to propose that:
EXCELLENCY the assurances of my highest consider- ation. Xxxxxxxx Xxxxxxx Xxx His Excellency the Minister for Foreign Affairs of the Federal Republic of Germany The Minister of Foreign Affairs of the People's Republic of Bangladesh Bonn, 6 May 1981 Excellency, I have the honour to inform you that the Government of the People's Republic of Bangladesh, in order to promote the making of investments by nationals or companies of the Federal Republic of Germany in the territory of the People's Republic of Bangladesh already prior to the entry into force of the Agreement, will apply the Agreement on a preliminary basis as from the date of its signature. This declaration of intent is made exclusively to enable the Government of the Federal Republic of Germany to consider guarantees for capital investments to be made in the People's Republic of Bangladesh prior to the entry into force of the Agreement. Accept, Excellency, the assurance of my highest consideration. Xxxxxxxx Xxxxxxx Xxx His Excellency the Minister for Foreign Affairs
EXCELLENCY. I have the honor to refer to the recent discussions between representatives of our two Governments concerning the Convention between the Government of the United States of America and the Government of the Republic of the Philippines with Respect to Taxes on Income, signed at Manila on October 1, 1976. It is our understanding that Philippine citizens residing outside of the Philippines are subject to Philippine tax on their worldwide income but at reduced rates of 1, 2, or 3 percent, and that foreign income taxes paid are deductible in computing their taxable income. We further understand that the Government of the Philippines, when applying paragraph 2 of Article 23 (Relief from Double Taxation) to such nonresident citizens, interprets the reference to “in accordance with the provisions of the law of the Philippines…” to allow the Government of the Philippines to continue to grant a deduction rather than a credit for U.S. taxes paid in such cases. We accepted this interpretation subject to confirmation by your Government that, should the present rates of Philippine income tax applicable to nonresident citizens of the Philippines be increased, the Government of the Philippines understands that the treaty would require a foreign tax credit and agrees to consult with the Government of the United States for the purpose of modifying this note to that effect. I have the honor to propose to you that the present note and your Excellency 's reply thereto indicating acceptance constitute the agreement of our two Governments on these various points. Accept, Excellency, the renewed assurances of my highest consideration. For the United States Government: XXXXXXX X. XXXXX. November 24, 1976. His Excellency the Xxxxxxxxx XXXXXXX X. SIMON, Secretary of the Treasury. EXCELLENCY: I have the honor to acknowledge receipt of your note of November 24, 1976, which reads as follows:
EXCELLENCY. I have the honour to acknowledge receipt of your Excellency’s note of October 7, 1996, concerning environmental issues at the four former U.S. mili- tary installations in Canada mentioned in your note. I have the honour to inform you that the United States Government’s pro- posal contained therein is acceptable to the Government of Canada. However, contrary to the views of the United States Government, it is the view of the Government of Canada that the Government of the United States has legal obligations under international law to pay claims for the environmental clean-up of these former U.S. military installations. I wish to assure you that the Government of Canada understands that the specific legislative authority, i.e. authorizations and appropriations, to which the United States’ ex gratia settlement is subject shall be a matter for decision by the United States Congress. The Government of Canada also understands that payment in full of the ex gratia settlement shall constitute a full and final settle- ment of all claims for costs of environmental clean-up at the four installations described. I have the honour to confirm that your note and this reply, done in duplicate in English and French, shall constitute an Agreement between the Governments of the United States and Canada on this matter, that enters into force on this date. Accept, Excellency, the renewed assurances of my highest consideration. Washington, D.C. October 9, 1996 TIAS 12806 Canadian Embassy Ambassade du Canada NOTE NO. 0318 EXCELLENCE, J’ai l’honneur d’accuser re´ception de la Note de votre Excellence du 7 octobre 1996 concernant les questions environnementales a` quatre anciennes installations militaires ame´ricaines au Canada mentionne´es a` votre Note. J’ai l’honneur de vous informer que la proposition du Gouvernement des E´ tats-Unis contenue dans la Note de votre Excellence agre´e au Gouvernement du Canada. Cependant, le Gouvernement du Canada xxxxxx, contrairement a` l’opinion du Gouvernement des E´ tats-Unis, que ce dernier a l’obligation le´xxxx, en vertu du droit international, de re´gler des indemnite´s pour la de´contamination de ces anciennes installations militaires des E´ tats-Unis. Je tiens a` vous assurer que le Gouvernement du Canada reconnaˆıt que l’autorite´ le´gislative spe´cifique, c’est-a`-dire les autorisations et les affectations de cre´dits, a` laquelle est assujettie le re`glement ex gratia des E´ tats-Unis est une question qu’il appartient au Congre`s des...
EXCELLENCY. 1. We are pleased to acknowledge on behalf of the International Bank for Reconstruction and Development (“IBRD”) as trustee of the Special Climate Change Fund (the “SCCF”) (the “Trustee”), the intention of Government of the Kingdom of Belgium, acting through its Directorate General of Development Cooperation, (the “Donor”) to make available to the Trustee the sum of Ten Million euro (EUR 10,000,000) (the “Contribution”) as a grant to the SCCF, which shall be allocated as set forth below.
EXCELLENCY. Bioscope creates innovative educational activities and devices, based on educational research and professional excellence, stimulates individual and collective creativity, and promotes the most recent results of scientific research.
EXCELLENCY. I have the honor to refer to the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington on November 20, 1975 and amended by a Protocol which was signed today. In the process of negotiating this Convention, the Israeli delegation emphasized the necessity of including in the Convention additional provisions, such as an investment credit for foreign investment, which will create incentives to promote the flow of investment to Israel. The United States delegation is not able to accept such provisions at this time. However, I wish to assure you that my Government realizes the importance your government attaches to the increase of investments in Israel. Should circumstances change, including any changes in the manner in which the United States imposes income tax upon the income of the United States investments in Israel, our Government would be prepared to re-open the discussions on provisions which would minimize the conflicts between the United States tax system and the incentives proposed by the Israeli Government to foreign investors and which would be consistent with the income tax policies of the United States, including treaty policies, with respect to other developing countries. I have the honor to propose that this note and your Excellency's reply confirming the above points of understanding on behalf of your Government shall be regarded as constituting an agreement between our two Governments concerning this matter, which will enter into force on the date of the entry into force of the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington November 20, 1975. Accept, Excellency, the renewed assurances of my highest consideration. For the Secretary of State:
EXCELLENCY. I have the honor to acknowledge your note of May 30, 1980, which reads as follows:
EXCELLENCY. I have the honor to refer to the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington November 20, 1975 and amended by a Protocol which was signed today, and to confirm on behalf of the Government of the United States of America, the following understanding reached between the two Governments. The competent authorities of each of the Contracting States shall review the procedures and requirements for an organization of the other Contracting State to establish its status as an eligible recipient of the charitable contributions described in Article 15-A with a view to avoiding duplicate application by such organizations to the administering agencies of both Contracting States. If a Contracting State determines that the other Contracting State maintains procedures to determine such status and rules for qualification that are compatible with such procedures and rules of the first- mentioned Contracting State, it is contemplated that such Contracting State shall accept the certification of the administering agency of the other State as to such status for the purpose of determining the deductibility or creditability of such charitable contributions. I have the honor to propose that this note and your Excellency's reply confirming the above points of understanding on behalf of your Government shall be regarded as constituting an agreement between our two Governments concerning this matter, which will enter into force on the date of the entry into force of the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington November 20, 1975. Accept, Excellency, the renewed assurances of my highest consideration. For the Secretary of State:
EXCELLENCY. I have the honor to refer to the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington on November 20, 1975 and amended by a Protocol which was signed today, and to confirm, on behalf of the Government of the United States of America, the following understanding reached between the two Governments. The Government of the United States and the Government of Israel agree that exchange of information shall be made in accordance with Article 29 (Exchange of Information) of the Convention. It is understood, however, that due to a lack of technical capability, and to a severe manpower shortage in revenue administration in Israel, it is impractical, at this time, for the Government of Israel to exchange information on a routine basis with respect to receipts from Israel of dividends, interest and royalties by residents of the United States as well as any information not existing in the Finance Minister's files. However, as soon as the above deficiencies are remedied, the Government of Israel will provide information made available by advances in its capability of acquiring and compiling tax information. I have the honor to propose that this note and your Excellency's reply confirming the above points of understanding on behalf of your Government shall he regarded as constituting an agreement between our two Governments concerning this matter, which will enter into force on the date of the entry into force of the Convention between the Government of the United States of America and the Government of the State of Israel with respect to taxes on income, signed at Washington November 20, 1975. Accept, Excellency, the renewed assurances of my highest consideration. For the Secretary of State: . THE SECRETARY OF STATE, The Department of State, Washington, D.C.
