Page:United States Statutes at Large Volume 47 Part 2.djvu/1009

 DOUBLE INCOME TAX-SHIPPING PROFITS-ITALY. 2599 Arrangement between the Unued States of America and Italy concerning _M~arc~h,,;-lo,~ll128__ . - the reliej jrom double income tax on shippi,ng profits. Effected by May 6,11128. exchange ojnotes dated March 10, 1926, and May 5, 1926. The Italian Ambassador (Ma,rtino) to the Secretary oj State (Kellogg) ROYAL ITALIAN EMBASSY ThIliAbd hi lim H · E I Double Income tal: e ta an m assa or presents s eomp ents to IS xee - on shipping profits. leney the Secretary of State and, referring to his note of June 24th, 1925, has the honor to bring to his knowledge the following. RI 1 From a communication received from the Italian Steamship Com- tlon~u~f=Sta~:~gd panies operating in ports of the United States it appears that the Italy. provisions contained m Royal Decree 891 issued on June 12, 1925, the text of which was 8ubInitted to the Department by the above men- tioned note, did not seem to the competent Departments of the Amer- ican Government to correspond exactly to the provisions contained in Section 213(b)(8) of the Revenue Act of 1921 and was therefore VoU2, p. 239. considered insufficient to obtain to the Italian Companies exemption from the payment of the Income Tax, retroactively to 1921, on the basis of reciprocity. In order to establish the required adequate basis of reciprocity, the Italian Government issued on March 4th, 1926 a Roval Decree N.340, the text of which is literally_ translated as follows: ~ "Companies organized in the United States and citizens of the "United States not domiciled in Italy exercising maritime traffic "in Italian ports, by means of ships Hying the United States "Hag are exempt, with effect starting from January 1st, 1921, "from the Imposta di Ricchezza Mobile, Income Tax, on income de- "rived escluslvely from such traffic, provided the United States "likewise exempt from Income Tax, Imposta di Ricchezza Mobile, "the income onginating in the United States to Italian citizens not "doIniciled in the United States and to Italian Companies, andde- "rived exclusively from the exercise of one or more ships flying the " I talian Ha~." The prOVIsions set forth in this Decree being exactly equivalent to those contained in Section 213, the Italian Government is confident that the competent American Authorities will extend to the Italian Steamship Companies operating in United States ports the treat- ment contemplated by Section 213 of the Revenue Act of 1921, and this with effect startmg from January 1st, 1921. The Italian Ambassador would much appreciate receiving some assurance in the matter. WASHINGTON D. C., Alarch 10th, 1926.