811.512362 Shipping/–
The German Embassy to the
Department of State
The German Embassy has the honor to forward herewith to the Department of
State an ordinance of the German Minister of Finance, III C 7412 of
August 10 of this year, together with an English
[Page 189]
translation, concerning the exemption of North
American Steamship Companies from the payment of the German corporation
tax.
Washington, September 13,
1923.
[Enclosure—Translation82]
The German Minister of Finance (Hermes) to the Presidents of the State
Finance Offices of Königsberg, Mecklenburg-Lübeck,
Oldenburg, Schleswig-Holstein, Stettin, Unterelbe, and
Unterweser
Berlin, August 10,
1923.
III C 7412Under section 213, subdivision 8, of the Revenue Act of 1921 of the
United States of America, the income derived exclusively from the
operation of a ship or ships of a foreign company is exempted from
the income tax if the company is subject to the laws of a foreign
state which grants reciprocal rights to the United States. At the
instance of the Embassy of the United States of America, I declare
myself as agreeing, upon the assumption of full reciprocity and with
the reservation of the right of revocation at any time, under
authority of section 108, subdivision 1, of the Federal Tax Law,
that in the case of companies operated for profit, whose domicile
and place of management is in the United States of America, the
income which is derived exclusively from the operation of ships
shall not be subjected to the corporation tax. A corporation-tax
return for the aforesaid income is not to be required of North
American companies which maintain in this country a branch or other
place of operation or a permanent representative. I request that the
finance offices charged with making the assessments be notified
forthwith.
If in individual cases doubt should arise, I ask that report be made
thereof.
Representing the Minister:
Zapf
