Page:United States Statutes at Large Volume 47 Part 2.djvu/1043

 DOUBLE INCOME TAX-SHIPPING PROFITS-GERMANY. Government of the United States of America as conveyed in the Embassy's Note Verhale No. 675 of May 5, 1924, and to cause in- structions to be issued to the subordinate finanf'ial authorities that the orderof August 10,1923, is to be applied to all companies which have their seat in the United States of America regardless of the loca- tion of their management. As concerns the conditions for abstention from collection of taxes from January 1,1921, referred to in the last-mentioned note verhale, the Foreign Office can only repeat the statement based on the official findings of the Federal Minister of Finance and contained in its Note No. V Steu 30 of January 19, 1924-the statement that since January 1, 1921, the income from the operation of ships of American shipping companies and citizens who have no residence in Germany has not been subjected to the German income tax or corporation tax. Fur- thermore, the German Government will abstain from a supplementary collection of taxes for the period since January 1, 1921, if the Amen- can Government grants reciprocity. The statement previously made by the Foreign Office through the usual diplomatic channels is a bind- in~official declaration of the German Government. The Foreign Office requests the Embassy of the United States of America to inform its Government of the above and to acquaint the Foreign Office with the American Government's attitude as soon as possible so that, if an agreement is reached between the German and American Governments, the Federal Minist.er of Finance may issue suitable instructions to the financial authorities. To BERLIN, September 3, 1924. THE EMBASSY OF THE UNITED STATES OF AMERICA. 2633 The American Embassy at Berlin to the German Ministry Jor Foreign y~.!ember 29. 1924. Affairs NOTE V ERBALE No. 935 V Steu 1489 With reference to the Note Verbale No. B34881 dated Sep- tember 3, 1924, of the Ministry for Foreip Affairs in regard to the taxation by Germany of the earnings denved from the operation of ships documented under the laws of the United States, the Embassv of the United States of America presents its compliments to the Ministry and has the honor to state that it lost no time in transmitti~ the Note Verbale under reference to the ~epartment of State and is now in receipt of instructions to invite the Ministry's attention to the follo~ observations of the Treasury Department of the United States Government: After careful consideration, this Department is of the opinion that in view of the categorical statement of the German Government and the :proposed amendment by the Commonwealth Minister of Finance to his order of August 10, 1923, Germany will meet the equivalent exemption provision of Section 213 (b) (8) of the Revenue Act of 1924, upon the issuance of the necessary orders referred to in the Note under consideration. The same opinion is herein expressed with respect to the years 1921, 1922 and 1923, under the provision of Section 213(b) (8) of the Revenue Act of 1921.