Page:United States Statutes at Large Volume 47 Part 2.djvu/1025

DOUBLE INCOME TAX-SHIPPING PROFITS-DENMARK, ETC. 2615 of ships documented under the laws of Denmark or Iceland, such taxes will be refunded to claimants. Accept, Sir, the renewed assurances of my highest consideration. 11'or the Secretary of State: MR. CONSTANTIN BRUN, Minister oj Denmark. "~ILLIAM PHILLIPS The Danish Minister (Brun) to the SecretaMJ oj State (Hughes) No. 290. SIR: ROYAL DANISH LEGATION, 'VASHINGTON, October 28th 1922. I have the honor to acknowledge the receipt of your reply-letter of October 25th with reference to the proposed exchange of notes between Denmark and the United States for the reciprocal exemp- tion of shipowners from income taxation, which has evidently crossed my note to you of October 24th on the same subject. In answer thereto I beg to state that the income from sources in Denmark and Iceland of a citizen of the United States or of an Ameri- can corporation, which consists exclusively of earnings derived from the operation of ships documented under the laws of the United States, is not and has not since January 1st 1921 or previously been subject to income taxation in Denmark, or in Iceland, and that my letter to you of October 24th should be so understood. I have the honor to be, Sir, with the highest consideration, Your most obedient and humble servant, THE HONORABLE CHARLES EVANS HUGHES, Secretary of State, C. BRUN . Department oj State, ll'"ashington, D. O. The Secretary oj State (Hughes) to the Danish !finister (Brun) SIR: DEPARTMENT OF STATE, WASHINGTON, December 5, 19£2. I have the honor to refer to your note of October 28, 1~22, in fur- Agreement by United ther reference to the proposed exchange of notes between the United State!;. States and Denmark for the reciprocal exemption of ship owners from income taxation, for which provision is made in Section 213(b) (8) of the Revenue Act of 1921, and to inform you of the receipt of a communication from the Treasury Department regarding the matter, from which the following paragraph is quoted for your information: "I have the honor to advise that inasmuch as the income from sources in Denmark and Iceland of a citizen of the United States or of a corporation organized therein which consists exclusively of earnings derived from the operation of ships documented under the laws of the United States is not and has not been subject to income tax since January I, 1921 or previouslY', it is held that Denmark and Iceland satisfy the equivalent exemptIOn provision of Section 213(b) (8) of the Revenue Act of 1921. In case any Federal income taxes have been collected from nonresident aliens or foreign corporations on income which consists exclusively of earnings derived on or since