5.} STAT.] PANAMA--TAX ON SHIPPING PROFITS- Jan15, Feb. 8 , 1941 Mar. 28, 1941 revenues derived from the operations of merchant ships from the tax imposed by Panamanian Law 49 of 1934. It is stated in the letter that these provisions "satisfy the equivalent exemption requirements of sections 212 (b) and 231 (d) of the Internal Revenue Code and the corresponding sections of the Revenue Act of 1938 and the Revenue Act of 1936". It is added that "Consequently, nonresident alien individuals (including citi- zens of the Republic of Panama) and foreign corporations (in- cluding corporations organized under Panamanian laws) are exempt from Federal income tax with respect to their income which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of Panama, for the years 1936 to 1940, inclusive. This ruling is equally applicable to subsequent years, as long as there remain in force and effect the provisions of the Executive Resolution No. 33 -bis of March 2, 1936, relative to the exemption from income tax of the reve- nues derived from the operations of merchant ships." Accept, Excellency, the renewed assurances of my highest con- sideration. For the Secretary of State: BRECKINRIDGE LONG His Excellency Sefior Dr. Don CARLOS N. BRIN, Ambassador of Panama. 1367 53 Stat. 76, 78. 26U. S. C. §§212 (b), 231 (d). 52 Stat. 528, 530. 49 Stat. 1715, 1717.
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