Context of Protocol amending tax convention with France : message from the President of the United States transmitting Protocol Amending the Convention between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed at Paris on August 31, 1994, as amended by the protocol signed on December 8, 2004, signed January 31, 2009, at Paris, together with a related memorandum of understanding, signed January 13, 2009