811.512332 Shipping/20

The American Chargé in Brazil (Schoenfeld) to the Brazilian Minister for Foreign Affairs (Mangabeira)

No. 1467

Mr. Minister: Referring to Your Excellency’s note No. NC/56 under date of May 31 of the current year, regarding exemption from income tax for foreign navigation companies, I have the honor to inform Your Excellency that I have just received the following request for information from the Department of State at Washington regarding the following points:

a)
Whether the exemption provided in. Decree No. 5623 applies to corporations organized in the United States which maintain a principal office or place of business, agency or branch office in Brazil;
b)
Whether under the Brazilian income tax law citizens of the United States are taxable or exempt with respect to the income derived by them from the operation of a ship or ships documented under the laws of the United States;
c)
Whether, if exempt, such exemption applies if the citizens of the United States maintain a principal office or place of business, agency or branch office in Brazil, and
d)
Whether it can be said that since December 29, 1928; the Brazilian Government has collected any income, war-profits or excess profits taxes from the income of a citizen of the United States or a corporation organized in the United States which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of the United States.

I shall be grateful to Your Excellency for the above information.

Accept [etc.]

Rudolf Schoenfeld