APPENDIX ARTICLE I The high contracting parties mutually agree that the income taxation imposed in the two States shall be subject to the following reciprocal provisions: (a) The rate of income tax imposed by one of the contracting States, in respect of income derived from sources therein, upon individuals residing in the other State, who are not engaged in trade or business in the taxing State and have no office or place of business therein, shall not exceed 5 per centum for each taxable year, so long as an equivalent or lower rate of income taxation is imposed by the other State upon individuals residing in the former State who are not engaged in trade or business in such other State and do not have an office or place of business therein. (b) The rate of income tax imposed by one of the contracting States, in respect of dividends derived from sources therein, upon nonresident foreign corporations organized under the laws of the other State, which are not engaged in trade or business in the taxing State and have no office or place of business therein, shall not exceed 5 per centum for each taxable year, so long as an equivalent or lower rate of income taxation on dividends is imposed by the other State upon corporations organized under the laws of the former State which are not engaged in trade or business in such other State and do not have an office or place of business therein. (c) Either State shall be at liberty to increase the rate of taxation prescribed by paragraphs (a) and (b) of this article, and in such case the other State shall be released from the requirements of the said paragraphs (a) and (b). (d) Effect shall be given to the foregoing provisions by both States as and from the 1st day of January, 1936. ARTICLE II The provisions of this convention shall not apply to citizens of the United States of America domiciled or resident in Canada. ARTICLE I This convention shall be ratified and shall take effect immediately upon the exchange of ratifications which shall take place at Washington as soon as possible. Signed, in duplicate, at Washington by the duly authorized representatives of the United States of America and Canada, this 30th day of December, in the year of our Lord, one thousand nine hundred and thirty-six. For the United States of America: R. WALTON Moore, Acting Secretary of State. For Canada: HEBBEET MABPE, Envoy Extraordinary and Minister Plenipotentiary. NOTE.- Exchange of ratifications occurred on August 18, 1937. TREATY WITH FRANCE Double taxation-Convention and protocol between the United States of America and France-Signed at Paris, April 27, 1932; ratification advised by the Senate of the United States, June 16, 1932; ratified by the President of the United States, July 25, 1932; ratified by France, April 8, 1936; ratifications exchanged at Paris April 9, 1936; proclaimed by the President of the United States, April 16, 1956. BY THB PRESIDENT OF THE UNITED STATES or AMERICA-A PBOCLh MATION. Whereas a convention between the United States of America and the French Republic to regulate certain questions relative to double taxation, and a protocol relating thereto, were signed by their respective plenipotentiaries at Paris on April 27, 1982, the original of which convention and protocol, being In the English and French languages, are word for word as follows: "The President of the United States of America and the President of the French Republic being desirous of regulating certain questions relative to double taxation, have decided to conclude a convention on that subject, and for that purpose they have appointed as their respective plenipotentiaries: 'The President of the United States of America, "Mr. Walter E. Edge, Ambassador Extraordinary and Plenipotentiary of the United States of America to France. 'The President of the French Republic, CLXXXV
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