The amending protocol to the France-US income and capital tax treaty of 31 August 1994 4 were submitted to the French Parliament on 14 December 2005.

The main purpose of the amending protocol to the income and capital tax treaty is to settle retroactively difficulties arising from the current tax treaty in respect of the taxation of partnerships. In addition, the amending protocol entitles French nationals who are US residents to deduct, from their taxable income in the US, the contributions paid to French retirement plans (rgimes de retraite).