Article 22 of this Convention contains significant anti-treaty-shopping rules making its

benefits unavailable to persons engaged in treaty-shopping. In addition, this Convention contains new provisions aimed at preventing abuse with respect to specific transactions. Under these new provisions, a person otherwise entitled to treaty benefits will be denied those benefits if the main purpose or one of the main purposes of the creation or assignment of the rights giving rise to the

income was to take advantage of the treaty.

This Convention also contains rules necessary for its administration, including rules for the resolution of disputes under the Convention (Article 25) and for exchange of information (Article 26).

The Convention would permit the General Accounting Office and the tax-writing committees of Congress (and analogous Slovenian authorities) to obtain access to certain tax information exchanged under the Convention for use in their oversight of the administration of tax laws.

This Convention is subject to ratification. In accordance with the provisions of Article 29, it will enter into force upon the exchange of instruments of ratification. With respect to taxes withheld at source, it will take effect for payments made or credited on or after the first day of the third month following the date on which the Convention comes into force; with respect to other taxes, the Convention will take effect for taxable periods beginning on or after the first day of January following the date on which the Convention enters into force.

This Convention, once ratified, will remain in force indefinitely unless terminated by one of the Contracting States, pursuant to Article 30. That Article provides that either State may terminate the Convention by giving prior notice through diplomatic channels.

The Department of the Treasury and the Department of State cooperated in the negotiation of the Convention. It has the full approval of both Departments.

Respectfully submitted,

MADELEINE ALBRIGHT.

LETTER OF TRANSMITTAL

THE WHITE HOUSE, September 13, 1999 .

To the Senate of the United States:

I transmit herewith for Senate advice and consent to ratification the Convention Between the United States of America and the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to: Taxes on Income and Capital, signed at Ljubljana on June 21, 1999. Also transmitted is the report of the Department of State concerning the Convention.

This Convention, which is similar to tax treaties between the United States and OECD nations, provides maximum rates of tax to be applied to various types of income and protection from double taxation of income. This Convention also provides for resolution of disputes and sets forth rules making its benefits unavailable to residents who are engaged in treaty-shopping or with respect to certain abusive transactions.

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

WILLIAM J. CLINTON.

CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND THE REPUBLIC OF SLOVENIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION

WITH RESPECT TO TAXES ON INCOME AND CAPITAL

The United States of America and the Republic of Slovenia, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, have agreed as follows: