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ARTICLE VI
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1. The last sentence of Paragraph 2 of Article 29 (Miscellaneous Provisions) of the
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Convention shall be deleted and replaced by the following:
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“For this purpose, the term “citizen” shall include a former citizen or long-term resident
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whose loss of such status had as one of its principal purposes the avoidance of tax (as
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defined under the laws of the United States), but only for a period of ten years following
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such loss.”
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2. Paragraph 3 of Article 29 (Miscellaneous Provisions) of the Convention shall be deleted
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and replaced by the following:
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“ 3. The provisions of paragraph 2 shall not affect:
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(a) the benefits conferred under paragraph 2 of Article 9 (Associated
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Enterprises), under paragraph 3 (a) of Article 13 (Capital Gains), under paragraph 1 of
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Article 18 (Pensions), and under Articles 24 (Relief From Double Taxation), 25
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(Non-Discrimination), and 26 (Mutual Agreement Procedure); and
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(b) the benefits conferred under paragraph 2 of Article 18 (Pensions), and under
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Articles 19 (Public Remuneration), 20 (Teachers and Researchers), 21 (Students and
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Trainees), and 31 (Diplomatic and Consular Officers), upon individuals who are neither
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citizens of, nor have immigrant status in, the United States.”