Country pairs / France / United States Unreviewed · applicability unverified
The last sentence in the final paragraph of paragraph 2 of Article 10 (Dividends) of the
Convention shall be deleted and replaced by the following new sentence:
“In the case of dividends paid by a United States real estate investment trust, the
provisions of subparagraph (b) shall apply only if:
(i) the beneficial owner of the dividends is an individual holding an interest
of not more than 10 percent in such real estate investment trust;
(ii) the dividends are paid with respect to a class of stock that is publicly
traded and the beneficial owner of the dividends is a person holding an
interest of not more than 5 percent of any class of the real estate
investment trust’s stock; or
(iii) the beneficial owner of the dividends is a person holding an interest of
not more than 10 percent in the real estate investment trust and the value
of no single interest in the real estate investment trust’s real property
exceeds 10 percent of the real estate investment trust’s total interests in
Citation to select or copy France / United States; IRS/Treasury official source publication; edition us-fr-2004-protocol; article ii; English; unreviewed source text, current applicability unverified; /editions/us-fr-2004-protocol/en/articles/article-ii/
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Source & edition IRS/Treasury official source publication
Retained native extraction Article provenance
Edition us-fr-2004-protocol Text available here English Review Unreviewed; qualified human review pending Current applicability Not verified Signature 2004-12-08 Currentness verified False Languages recorded in source metadata: English, Français. This is not a promise of available text or a translation.
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