DOUBLE INCOME TAX-SHIPPING PROFITS-FRANCE. there is a coPy of a despatch dated May 24, 1927, from the American Embassy at Paris, enclosing a copv and translation of a decree of the French Government dated :May 20, 1927, exempting the income of American ship owners from taxation. Attached t.o your letter of June 23, 1927, there is a copy of the decree issued by the French Government on May 20, 1927, and published in the o}fid.al Journal of the French Republic of May 23 and 24, 1927. You request to be informed whether the decree is satisfactory, in order that you may advise the Chal1!e d'Affaires of the French Embassy ~hat French citizens, not reSIdents in United States and French corporations will be exempt from income taxes on profits derived from shipping. The decree adopted May 20, 1927, follows the wording of the decree submitted to this Department ",ith your letter of :March 26, 1927. You were advised on April 9, 1927, that the decree if adopted in the form submitted would meet the equivalent exemption require- ments of section 213 (b) (8) of the Revenue Acts of 1921, 1924, and 1926. The Charge d'Affaires states in his note that the decree goes into immediate effect in France. I have the honor to advise you that in view of the fact that the French Government has adopted the decree in the form submitted and it is now in effect, it is held that France satisfies the equivalent exemption provision .of section 213 (b) (8) of the Revenue Acts .of 1921, 1924 and 1926." It will be observed that the Treasury Department holds that in view .of the fact that the French Government has ad.opted a decree .of exempti.on which is now in effect, the French Government has satisfied the equivalent exemption provision of Section 213 (b) (8) .of the Revenue Acts of 1921, 1924, and 1926. Accept, Sir, the renewed assurances of my high consideration. For the Secretary of State: w. R. CASTLE, JR. COUNT DE SARTIGES, Charge d'Affaires ad interim oj France. [No. 12) 2607
