Page:United States Statutes at Large Volume 47 Part 2.djvu/1019

DOUBLE INCOME TAX-SHIPPING PROFIT~REECE. the profits derived from maritime enterprises, on the basis of reci- proClty. Greek law contains the following exemptions on this subject: 1. Article 30, paragraph 8 of Law No. 3338 of June 15, 1925: "The ordinance in paragraph 7 of Article 3 of this law has retro- active effect with respect to the income tax of the years 1919-1920 up to 1924-1925, as well as that of excess profits of the vear 1915 and the following years, and also with respect to the addfticnal ta.'l{ on corporations of the year 1921 and the following years." 2. The ordinance of Article 3, paragraph 7 of Law No. 3338 above mentioned, ends as follows: "To paragraph 3 of Article 18 of Law 1640 concerning the taxa- tion of Income there is added as the sixth case the following exemp- tion. Sixth case: 'In virtue of reciprocity, profits made in Greece by vessels flying a foreign flag.' " The two ordinances mentioned above guarantee the exemption of foreign shipping concerns in virtue of reciprocity. The income tax has been in force since 1919-1920, that is to say, since the date for which retroactive effect was stipulated in the law. The tax on excess profits was in force from 1915 until 1923, and the additional tax on corporations from 1921 until 1924. HIS EXCELLENCY MR. FRANK B. KELLOGG Secretary oj State, etc., etc. lrashington, D. C. The Secretary oj State (Kellogg) to the Greek Minister (Simopoulos) [Extract) DEPARTMENT OF STATE, WASHINGTON, April 26, 1928. The Secretary of State presents his compliments to the Greek Minister and has the honor to refer to the Minister's note of February 29, 1928, setting forth the provisions of the Greek income tax law exempting from taxation earnings made in Greece by ships flying a foreign flag. The Secretary of State has the honor to inform the Greek Minister that before it can be determined whether these exemptions are equivalent to the exemptions that may be accorded bv the United States under Section 213(b)(8) of the Revenue Acts wof 1921 and 1924 it will be necessary for the appropriate authorities of the Government to be informed as to whether: (a) during the years 1921-1924, inclusive, taxes have been col. lected by the Greek Government from the revenues of American citizens not residing in Greece or of corpora. - tions organized under the laws of the United States, derived from the operation of ships documented under the laws of the United States; (b) the exemption provided in Article 3, Pa.ragraph 7 of the Law, No. 3338 applies to the profits derived by a citizen of the United States not residing in Greece, and to corpo- rations organized under the laws of the United States, or whether in the case of such citizen the exemption only applies if he resides in the United States; (c) the exemption applies in cases where citizens of the United States or corporations organized under the laws of the United States maintain agencies, branch offices, or repre- senta.tives in Greece, in connection with the operation of ships documented under the laws of the United States. 2609