STATEMENT OF INTENT 

At the signing today of the Agreement between the Government of the United States of 

America and the Government of the French Republic to Improve International Tax 

Compliance and to Implement FATCA (hereafter referred to as "the Agreement"), the 

Government of the French Republic and the Government of the United States of America 

have declared their intention to interpret the provisions of the Agreement as follows. 

With reference to subparagraph 2(b) of Article 2 of the Agreement 

When U.S. law authorizes reporting of any of the information in respect of which the 

United States expressed its commitment to pursue reciprocity in paragraph I of Article 6 

of the Agreement, including account balance, the United States is committed to report 

such additional information to the French Competent Authority in conjunction with the 

information reported under subparagraph 2(b) of Article 2 of the Agreement. 

With reference to paragraph 6 of Article 3 of the Agreement 

France and the United States intend the agreement between the Competent Authorities 

called for in paragraph 6 of Article 3 of the Agreement, which refers to the establishment 

of procedures for the implementation of the automatic exchange obligations under the 

Agreement, to include procedures relating to the structure o f the data transmitted. 

With reference toparagraph I of Article 10 of the Agreement 

The Government of the United States of America understands that the Government of the 

French Republic plans to present the Agreement to its parliament for its approval in 2013 

and to propose implementing legislation with the goal of having the Agreement and such 

implementing legislation enter into force by September 30, 2015. Therefore, as of the date 

of signature of the Agreement, the United States Department of the Treasury intends to 

treat each French Financial Institution, as that term is defined in the Agreement, as 

complying with, and not subject to withholding under section 1471 of the U.S. Internal 

Revenue Code during such time as France is pursuing the necessary internal procedures 

for entry into force of the Agreement. The United States further understands that France's 

Ministry of Finance expects to contact the United States Department of the Treasury as 

soon as it is aware that there might be a delay in the French internal approval process for 

entry into force of the Agreement such that France would not be able to provide its 

notification under paragraph l of Article I 0 of the Agreement prior to September 30, 

2015. If upon consultation with France, the United States receives credible assurances that 

such a delay is likely to be resolved in a reasonable period of time, the United States 

Department of the Treasury may decide to continue to apply FA TCA to French Financial 

Institutions in the manner described above as long as the United States Department of the 
Treasury assesses that France is likely to be able to send its notification under paragraph I 

of Article 10 by September 30, 2016. Should the Agreement enter into force after 

September 30, 2015, any information that would have been reportable under the 

Agreement thereafter (and prior to its entry into force) had the Agreement been in force by 

September 30, 2015, is owed on the September 30 next following the date of entry into 

force. 

With reference to subparagraph B(4)0) of section VI of Annex I 

The signing Governments expect that any recognized not-for-profit organization 

mentioned in paragraph 2(ii) of Article 4 of the Convention between the Government of 

the United States of America and the Government of the French Republic for the 

A voidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to 

Taxes on Income and Capital, meets the criteria set forth in subparagraph B(4)U) of 

section VI of Annex I (Active NFFE). 

Signed at Th,;6 

of o~tM \t(, 2013. 

, in duplicate, in the English and French languages, this if day 

FOR THE GOVERNMENT OF THE 

UNITED STATES OF AMERICA: 

) 

4~ 

FOR THE GOVERNMENT OF THE 

FRENCH REPUBLIC: 

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