Page:United States Statutes at Large Volume 47 Part 2.djvu/1012

 2602 DOUBLE TAX-SHIPPING PROFITS-NETHERLANDS. The Treasury Department states that the decree as submitted to it meets the equivalent exemption requirements of Section 213(b)(8) of the United States Revenue Act!g of 1921, 1924 and 1926. I shall be 'pleased to have you inform me when the decree is issued. Accept, Sir, the renewed assurances of my high consideration. For the Secretary of State: JOSEPH C. GREW JONKHEER DR. H. VAN ASCH VAN \VYCK, Charge d' AjJaires ad interim oj ihe Netherlands. The Charge d'AjJa,ires ad interim of the Netherlands (van IVyck) to the Secretary oj State (Kellogg) No. 3219. SIR: THE NETHERLAND LEGATIOX, \VASHINGTON, October 19, 1926. N~t~::Ct by the I had the honor to receive you note of September 13, 1926 by which you informed me of the receipt of a communication from the Treasury Department regarding the draft of a Roval Decree, with English translation, to be issued by Her Majesty the Queen of the Netherlands, relative to the prevention of double taxation on income derived excluoively from the operation of ships, which was left at the Treasury Department on July 29, 1926. In this note you stated that the English translation of the proposed decree reads as follows: "We, Wilhelmina, by the Grace of God, Queen of The Nether- lands, Princess of Orange-Nassau etc. etc. "Whereas it is provied in the Unique Section of the Law of June 26, 1926, (Statute book No. 209), that we reserve Ourselves under No.2 to make provisions, on a basis of reciprocity, preventing double taxation on earnings derived from the operation vf ships, corre- sponding with equivalent provisions existing in the laws of foreign nations j and "Whereas under Section 213, litt. b, No. 8 of the Revenue Act of the United States no tax is imposed on the income of an alien individ- ual non-resident in the United States or of a foreign corporation which consists exclusively of earnings derived from the operation of a ship or ships docu~ented under the laws of a foreign country which grants an equiv~lent exemption to citizens of the United States and to corporations organized in the United States, do hereby proclaim and make known: "UNIQUE SECTION "CITIZENS OF THE UNITED STATES NON·RESIDENT IN THE NETHERLANDS AND CORPORATIONS OUOANIZED IN THE UNITED STATES WHICH EFFECTUATE IN THE NETHERLANDS THE SEA TRANSPORT WITH SHIPS DOCl"MENTED UNDER THE LAW OF THE UNITED STATES ARE (WITH RETROACTIVE POWER TILL JANU· ARY 1. 1921) NOT SUBJECT TO TAXATION AS FAR AS INCOME DERIVED EXCLl:SrVELY FROM SUCH INDUSTRY IS CONCERNED." You further informed me that the Treasury Department states that it interprets the proposed decree as exempting from tax the income from sources within the Netherlands received by citizens of the United States non-resident in the Netherlands and by corpo- rations organized in the United States, which consists exclusively of earnings derived from the operation of ships documented under the laws of the United States, such exemption applying to income