Message to the Senate Transmitting the United States-Denmark Convention on Taxation and Fiscal Evasion

September 8, 1983

To the Senate of the United States:

I transmit herewith, for Senate advice and consent to ratification, the Convention between the Government of the United States of America and the Government of the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Estates, Inheritances, Gifts and Certain Other Transfers, signed at Washington on April 27, 1983.

The Convention is the first of its kind to be negotiated between the United States and Denmark. It will apply, in the United States, to the Federal estate tax, the Federal gift tax, and the Federal tax on generation-skipping transfers and, in Denmark, to the duty on inheritances and gifts.

A principal feature of the Convention is that the country of the transferor's domicile may tax transfers of estates and gifts and generation-skipping transfers on a worldwide basis, but must credit tax paid to the other State on the basis of location or situs of specified types of property.

I recommend that the Senate give early and favorable consideration to the Convention and give its advice and consent to ratification.

Ronald Reagan

The White House,

September 8, 1983.