III 

112TH CONGRESS 

1ST SESSION S. RES. 108 

Expressing the sense of the Senate on the importance of strengthening 

investment relations between the United States and Brazil. 

IN THE SENATE OF THE UNITED STATES 

MARCH 17, 2011 

Mr. LUGAR submitted the following resolution; which was referred to the 

Committee on Foreign Relations 

RESOLUTION 

Expressing the sense of the Senate on the importance of 

strengthening investment relations between the United 

States and Brazil. 

Whereas President Barack Obama is set to visit Brazil on 

March 19 and 20, 2011, during a 5-day trip which will 

include stops in Chile (March 21), and El Salvador 

(March 22); 

Whereas the United States and Brazil enjoy longstanding 

economic relations sustained by trade and investment; 

Whereas investment in and by Brazil promotes economic 

growth, generates greater wealth and employment, 

strengthens the manufacturing and services sectors, and 

enhances research, technology, and productivity in the 

United States and Brazil; 


smartinez on DSKB9S0YB1PROD with BILLS
2 

•SRES 108 IS 

Whereas the United States is the largest direct investor 

abroad, with total world-wide investments of 

$3,508,000,000,000 in 2009; 

Whereas the United States has historically been the largest 

direct investor in Brazil, investing a total of 

$56,692,000,000 in 2009; 

Whereas the sound economic policy of the Government of 

Brazil was given an investment-grade rating by the 3 

major investment rating agencies in 2009; 

Whereas the United States is the largest recipient of direct 

investment in the world, with total foreign direct investments of $2,320,000,000,000 in 2009; 

Whereas the United States received direct investment from 

Brazil, including a total of $1,400,000,000 in 2007 and 

a reduction of that amount by $647,000,000 in 2009; 

Whereas Brazil is the only country with a gross national 

product of more than $1,000,000,000,000 with which the 

United States does not have a bilateral tax treaty; 

Whereas Brazil is the 4th largest investor in United States 

Treasury securities, which are important to the health of 

the United States economy; 

Whereas Brazil ranked 7th among other countries in the 

number of corporations listed on the New York Stock Exchange in 2009, with 35 corporations listed; 

Whereas a bilateral tax treaty between the United States and 

Brazil would enhance the partnerships between investors 

in the United States and Brazil and benefit small- and 

medium-sized enterprises in both the United States and 

Brazil; 


smartinez on DSKB9S0YB1PROD with BILLS
3 

•SRES 108 IS 

Whereas a bilateral tax treaty between Brazil and the United 

States would promote a greater flow of investment between Brazil and the United States by creating the certainty that comes with a commitment to reduce taxation 

and eliminate double taxation; 

Whereas the Brazil-United States Business Council and the 

United States-Brazil CEO Forum have worked to advance a bilateral tax treaty between the United States 

and Brazil; 

Whereas the Senate intends to closely monitor the progress 

on treaty negotiations and hold a periodic dialogue with 

officers of the Department of the Treasury; and 

Whereas the United States and Brazil will greatly benefit 

from deeper political and economic relations: Now, therefore, be it 

1 Resolved, That it is the sense of the Senate that— 

2 (1) the United States Government and the Gov3 ernment of Brazil should continue to develop their 

4 relationship; and 

5 (2) during the President’s March 19 and 20, 

6 2011, visit to Brazil, he should propose to his Bra7 zilian counterpart that the United States and Brazil 

8 begin negotiations for a bilateral tax treaty that— 

9 (A) is consistent with the existing tax trea10 ty practices of the United States Government; 

11 and 


smartinez on DSKB9S0YB1PROD with BILLS
4 

•SRES 108 IS 

1 (B) reflects modern, internationally recog2 nized tax policy principles. 

Æ 


smartinez on DSKB9S0YB1PROD with BILLS