This is a technical explanation of the Protocol and the related Memorandum of Understanding signed at Paris on January 13, 2009 (hereinafter the "Protocol" and "Memorandum of Understanding" respectively), amending the Convention between the Government of the United States of America and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, signed at Paris on August 31, 1994, as amended by the Protocol signed on December 8, 2004 (together, the "existing Convention").