The US Treasury Department announced on 13 January 2009, that France and the United States signed a protocol to the income and capital tax treaty signed on 31 August 1994 as amended by the protocol signed on 8 December 2004. In addition, the two countries signed a memorandum of understanding (MoU) with rules and procedures for implementing the new binding arbitration process added by the protocol for unresolved mutual agreement cases. The protocol is considered an update to bring the treaty in line with current tax treaty policy. The protocol makes several modifications throughout the treaty, with significant updates to...