2672 63 Stat. 76, 78. 26U..0.J.212 (b), 231 (d). INTERNATIONAL AGREEMENTS OTHER THAN TREATIES [61 STAT. Accept, Excellency, the renewed assurances of my highest con- sideration. K. T . JUTLA. His Excellency The Honorable JAMEs F. BYRNES The Secretary of State The Departmentof State Washington The Secretary of State to the Finnish Minister DEPsAnrENT or STATE WASHINGTON January7 1947 SIR: I have the honor to refer to your note dated June 6, 1946, relating to the desire of the Government of Finland to enter into an agreement with the Government of the United States of America relating to reciprocal exemption from double taxation on shipping profits. A copy of your note was sent to the Secretary of the Treasury with a view to obtaining an expression of the views of the Treasury Depart- ment with respect to this matter. A letter dated October 30, 1946 has been received from the Treasury Department in which, after refer- ences to the Legation's note and to the Finnish income tax law cited in that note, and to section 3 of the Finnish Law of December 5, 1924 on the same subject, it is pointed out that the corresponding provisions of United States income tax law provide in the case of a nonresident alien or foreign corporation for exemption of earnings derived from the operation of ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States of America and to corporations organized in the United States of America. (Section 212 (b) and section 231 (d), Internal Revenue Code.) The Treasury Department's letter contains the following statement: "It is the view of this Department that from the date specified in your reply note to the Finnish Legation, Finland will satisfy the equivalent exemption provisions of section 212 (b) and 231 (d) of the Internal Revenue Code, and hence that the Government of the United States may give to the Government of Finland assurances that the income of Finnish nationals and Finnish corporations which consists exclusively of earnings derived from the operation of ships documented under the laws of Finland will be exempt from United States income tax from such specified date." It is, therefore, the view of the Government of the United States of America that Finland meets the requirements, with respect to recip- rocal exemption, of the applicable United States revenue laws, and consequently that the income of Finnish nationals and corporations
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