Page:United States Statutes at Large Volume 47 Part 2.djvu/1020

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2610 DOUBLE INCOME TAX-SHIPPING PROFITS-GREECE. In this connection the Secretary of State has the honor to state that he has been informed by the appropriate authorities of the Government that if it is eventually determined that the pertinent exemptions in the Greek income tax law are equivalent t.o the exemption provision of Section 213(b)(8) of the Revenue Acts of 1921 and 1924 it will be unnecessary for the United States to con- clude any agreement with Grecce relative to the exemption of earnings derived from the operation of ships documented under the laws of the two countries. • • • if the Greek Minister will supply the additional informution needed the appropriate authorities of the Government will be able to arrive at a definite decision with reference to the general question of the exemption of earnings made in the United States by ships flying the Greek flag. The Greek jl1im·ster (S1:mopoulOf;) to tlte Secretary oj Statf' (Sf1"mson) No. 422 LEGATION OF GREECE, WASHINGTON, April 2, 1929. The Minister of Greece presents his compliments to His Excellency the Secretary of State and, referring to the Department's Note of April 26, 1928, No. 811.512368 Shipping/4, has the honor to inform that the exemptions of the Greek law are equivalent to the exemp- tions that may be accorded by the United States under Section 213(B)(8) of the Revenue Acts of 1921 and 1924. Concerning the De'partment's inquiry as to whether "A" during the years 1921-1924 mclusive, taxes have been collected by the Greek Government from the revenues of American citizens residing in Greece or of corporations organized under the laws of the United States, derived from the operation of ships documented under the laws of the United States, the Minister of Greece is authorized to state that for the years 1921-1924 inclusive, no taxes have been col- lected by the Greek Government from the revenues of American citizens whether residing in Greece or not, or of shipping corpora- tions organized under the laws of the United States for revenues deriving from operation of American ships in Greece. With r~ard to question "B" whether t.he exemption provided in Article 3, Paragraph 7 of the Law No. 3338 applies to the profits derived by citizens of the United States not reSIding in Greece, and to corporations organized under the laws of the United States or whether in the case of such citizens the exemption only applies if he resides in the United States, the Minister of Greece is authorized to state that the exemption provided in Article 3, Paragraph 7 of the Greek Law No. 3338 is applied on the profits derived by a citizen of the United States whether residing in Greece or not as well as to the shippin~ companies organized under the American laws. As to questIOn" C" whether the exemption applies in cases where citizens of the United States or corporatiollS o~anized under the laws of the United States maintain agencies, Dranch offices, or representatives in Greece, in connection with the operation of ships documented under the laws of the United States, the Minister of Greece is authorized to state that the exemption is applied generally not only for the American citizens and the American shipping enter- prise but on the American ships in Greece. Accordingl~ it is determined that the pertinent exemptions in the Greek Income Tax Law are equivalent to the exemption provisions of Section 213 (b) (8) of the Revenue Acts of 1921 and 1924.