NOTES OF EXCHANGE (PROTOCOL 1) 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
颁布时间:1980-05-30
May 30, 1980.
HIS EXCELLENCY
EPHRAIM EVRON,
Ambassador of Israel.
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:
(s) HAROLD H. SAUNDERS.
EMBASSY OF ISRAEL
Washington, D.C., June 2, 1980.
THE SECRETARY OF STATE,
The Department of State,
Washington, D.C.
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 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 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."
I confirm these understandings on behalf of the Government of Israel.
These understandings constitute an agreement between our two Governments
on this matter, which will enter into force on the date of entry into
force of the Convention between the Government of the State of Israel and
the Government of the United States of America with Respect to Taxes on
Income signed at Washington on November 20, 1975.
Accept, Excellency, the renewed assurances of my highest
consideration.
EPHRAIM EVRON,
Ambassador.
MAY 30, 1980.
HIS EXCELLENCY
EPHRAIM EVRON,
Ambassador of Israel.
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 firstmentioned 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:
(s) HAROLD H. SAUNDERS.
EMBASSY OF ISRAEL
Washington, D.C., June 2, 1980.
THE SECRETARY OF STATE,
The Department of State,
Washington, D.C.
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 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 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 firstmentioned 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."
I confirm these understandings on behalf of the Government of Israel.
These understandings constitute an agreement between our two Governments
on this matter, which will enter into force on the date of entry into
force of the Convention between the Government of the State of Israel and
the Government of the United States of America with Respect to Taxes on
Income signed at Washington on November 20, 1975.
Accept, Excellency, the renewed assurances of my highest
consideration.
EPHRAIM EVRON,
Ambassador.
MAY 30, 1980.
HIS EXCELLENCY
EPHRAIM EVRON,
Ambassador of Israel.
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:
(s) Harold H. Saunders
EMBASSY OF ISRAEL,
Washington, D.C., May 30, 1980.
.
THE SECRETARY OF STATE,
The Department of State,
Washington, D.C.
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 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 understandings 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 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.
I confirm these understandings on behalf of the Government of Israel.
These understandings constitute an agreement between our two Governments
on this matter, which will enter into force on the date of entry into
force of the Convention between the Government of the State of Israel and
the Government of the United States of America with Respect to Taxes on
Income signed at Washington on November 20, 1975.
Accept, Excellency, the renewed assurances of my highest
consideration.
Sincerely,
EPHRAIM EVRON,
Ambassador.