ARTICLE III

1. The following shall be added to paragraph 2 of Article 10 (Dividends) of the Convention, immediately preceding the last sentence of the paragraph: “Subparagraph (a) shall not apply in the case of dividends paid by a United States Regulated Investment Company or Real Estate Investment Trust. Subparagraph (b) shall apply in the case of dividends paid by a Regulated Investment Company. In the case of dividends paid by a Real Estate Investment Trust, subparagraph (b) shall apply if the beneficial owner of the dividends is an individual holding a less than 10 percent interest in the Real Estate Investment Trust; otherwise the rate of tax applicable under domestic law shall apply."

2. The second sentence of paragraph 5 of Article 10 (Dividends) of the Convention shall be deleted and replaced by the following: "In addition, a company which is a resident of Barbados shall be exempt from United States accumulated earnings tax if individuals (other than United States citizens) who are residents of Barbados control directly or indirectly throughout the last half of the taxable year more than 50 percent of the entire voting power or value of the company."

3. Paragraph 6 of Article 10 (Dividends) shall be deleted and replaced by the following: "6. Where a company that is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or are attributable to a

permanent establishment or a regular base situated in that other State, even if the dividends paid consist wholly or partly of profits or income arising in such other State."