The decree of which your Excellency will find a copy herewith reproduces
the wording quoted in my letter of January 19,17 which has been acknowledged by
the United States Department of the Treasury as meeting the conditions
required by Section 213 (b) (8) of the Revenue
Act of 1921, 1924, and 1926 for the granting of an equivalent exemption
in the United States.
Under these conditions I should be glad if your Excellency would kindly
give me the assurance that the French citizens and French companies will
hereafter be exempt from the tax on profits derived from navigation
business.
[Enclosure—Translation18]
Decree Issued by the French Government, May 20,
1927
The President of the French Republic,
On the report of the President of the Council, Minister of
Finance,
Considering Article 5 of the finance law of April 29, 1926,
Decrees:
Art. 1.—Citizens of the United States of
America not domiciled on the territory of the French Republic, as
well as juridical persons
[Page 706]
organized in the United States of America, who exploit within the
limits of the territory of the French Republic, navigation
enterprises, with ships navigating under the American flag, are
exonerated from any tax on the profits accruing exclusively from
navigation.
This exoneration, which, by way of reciprocity, shall take effect
from January 1, 1921, concerns, notably, the tax on industrial and
commercial profits instituted by heading 1 of the law of July 31,
1917, and the tax on income prescribed by the law of June 29, 1872,
and the decree of December 6, 1872, as payable by foreign companies,
whose shares are not quoted, but who possess movable or immovable
property situated in France.
Art. 2.—The present decree will be
submitted to the ratification of the Chambers, in conformity with
the provisions of Article 5 of the law of April 29, 1926.
Art. 3.—The President of the Council,
Minister of Finance, is charged with the execution of the present
decree, which will be published in the Journal
Officiel and inserted in the Bulletin des
Lois.
Done at Paris,
May 20,
1927.
Gaston Doumergue
By the President of the Republic:
Raymond Poincaré
The President
of the Council, Minister of Finance
