LEGISLATIVE HISTORY OF UNITED STATES TAX CONVENTIONS INTRODUCTION The Legislative History Of United States Tax Conventions is a compilation of legislative history materials relating to the various tax conventions to which the United States is a signatory. Parts I, II, and III contain materials relating, respectively, to income tax conventions, death tax conventions and gift tax conventions. The first section in each of these parts contains general information relating to conventions of the type covered by that part, and includes tabulations of significant dates and reference material concerning those conventions, as well as certain Congressional materials relating generally to the United States tax treaty program. Each of the other sections in these three parts covers a country with which the United States has signed a tax convention, and includes the verbatim text of each (1) Presidential message of transmittal to the Senate, (2) Senate committee hearing, (3) Senate committee executive report, (4) Senate floor debate, and (5) Presidential proclamation, pertaining to any convention or protocol signed by the United States and that country. It should be noted that the materials in these three parts include only those resulting from the processing of conventions by the Government of the United States. As a consequence, this document does not contain that portion of the legislative history of United States tax conventions resulting from the processing of those conventions by governments of the other countries involved. Part IV contains materials relating to work on model tax conventions done under the auspices of international organizations such as the League of Nations, the Organisation for European Economic Cooperation (OEEC), and the Organisation for Economic Cooperation and Development (OECD). These materials include the texts of, and commentaries on, model convention provisions, as well as other related materials. To facilitate citation to materials in documents reproduced in this compilation, original page numbers of those documents have been retained. In the case of proceedings on the Senate floor, page numbers of the Congressional Record in which the proceedings were reported have been inserted in brackets at the appropriate places within the text of the material. The materials included in this document, although frequently needed for purposes of interpreting or tracing the development of provisions of tax conventions, have generally been difficult to obtain and in many cases have been unavailable. This document has been prepared to meet the need for a compilation of such materials. by the Staff to facilitate understanding and analysis of treaty tax law of the United States. The first document, entitled A Topical Comparison of United States Income Tax Conventions and published under date of November 1, 1960, may also be useful to those who have occasion to use this document. DALE W. WICKHAM Attorney to the Joint Committee WASHINGTON, December 1, 1961. on Internal Revenue Taxation. |