60 STAT.] UNITED KINGDOM-DOUBLE TAXATION- Apr 16 1945 June 6, 1946 Convention between the United States of America and the United King- dom respecting double taxation and taxes on income and protocol. Signed at Washington April 16, 1945 and June 6, 1946, respectively; ratification advised by the Senate of the United States of America June 1, 1946, and June 19, 1946, respectively; ratified by the President of the United States of America June 26, 1946; ratificationsexchanged at Washington July 25, 1946; proclaimed by the Presidentof the United States of America July 30, 1946. BY THE PRESIDENT OF THE UNITED STATES OF AMERICA A PROCLAMATION WHEREAS a convention between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed by their respective Plenipo- tentiaries at Washington on April 16, 1945; AND WHEREAS a supplementary protocol modifying in certain respects the said convention was signed by the respective Plenipo- tentiaries of the United States of America and the United Kingdom of Great Britain and Northern Ireland at Washington on June 6, 1946; AND WHEREAS the originals of the said convention and the said supplementary protocol are word for word as follows: The Government of the United States of America and the Govern- ment of the United Kingdom of Great Britain and Northern Ireland, Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have appointed for that purpose as their Plenipotentiaries: The Government of the United States of America: Mr. Edward R. Stettinius, Jr., Secretary of State, and The Government of the United Kingdom of Great Britain and Northern Ireland: The Right Honorable the Earl of Halifax, K.G., Ambassador Extraordinary and Plenipotentiary in Washington, Who, having exhibited their respective full powers, found in good and due form, have agreed as follows: ARTICLE I (1) The taxes which are the subject of the present Convention are: (a) In the United States of America: The Federal income taxes, including surtaxes and excess profits taxes (hereinafter referred to as United States tax). (b) In the United Kingdom of Great Britain and Northern Ireland: 1377 April 16, 1945, and June 6, 1946 [T.I.A.S.146 Plenlpotentiarie.
�
