Page:United States Statutes at Large Volume 47 Part 2.djvu/1024

2614 DOUBLE INCOME TAX-SHIPPING PROFITS-DENMARK, ETC. The Danish, Minister (Brun) to the Secretary oj States (Hughes) No. 284. ROYAL DANISH LEGATION, WASHINGTON, October £4.th 1922. SIR: With further reference to your reply-note of August 9th 1922 relative to the reciprocal exemption of shipowners from income tax as from January 1st 1921, in accordance with Section 213 b 8 of the Revenue Act of 1921, and pursuant to instructions now received from the Danish Minister of Foreign Affairs, I have the honor to declare on behalf of the Danish Government that the income from sources in Denmark and Iceland of a citizen of the United States or of an American corporation, which consists exclusively of earn- ings derived from the operation of ships documented under the laws of the United States, is not subject to income taxation in Denmark or in Iceland. In these circumstances I venture to hope that you will state in a note to me, for the information of the Danish Government, that Denmark and Iceland satisfy the equivalent exemption provision of Section 213 b 8 of the Revenue Act of 1921 and that Danish and Icelandic shipowners will be exempted from income tax in the United States as provided in the said Section as from January 1st 1921, in accordance with the letter (No. 236) which I had the honor to address to you on August 18th 1922. I have the lionor to be, Sir, with the highest consideration, Your most obedient and humble servant, THE HONORABLE CHARLES EVANS HUGHES, Secretary oj State, C. BRUN . Department oj State, Washington, D. O . The Secretary oj State (Hughes) to the Danish Minister (Brun) DEPARTMENT OF STATE, WA8HINGTON, October 25 1922. SIR: I have the honor to refer to your note of August 18, 1922, in which, with reference to the proposed exchange of notes between the United States and Denmark for the reciprocal exemption of ship owners from income taxation, you request the Department to confirm the under- standing of the Danish Government that this exemption, when estab- lished, would be as from January 1, 1921, notwithstanding the fact that the actual exchange of notes can not be arranged until some later date. I have the honor to state that upon receipt of a note from the Danish Government declaring that the income from sources in Den- mark and Iceland of a citizen of the United States or of an American corporation, which consists exclusively of earnings derived from the operation of ships documented under the laws of the United States, has since January 1, 1921, not been subject to income taxation in Denmark, or in Iceland, the Treasury Department will issue a state- ment that Denmark and Iceland satisfy the equivalent exemption provision of Section 213 (b) (8) of the Revenue Act of 1921. In case Income taxes have been collected by this Government from non-resi- dent aliens or foreign corporations on income which consists exclu- sively of earnings derived since January 1, 1921, from the operation