811.512365 Double/5

The Secretary of State to the Italian Ambassador (Rosso)

The Secretary of State presents his compliments to His Excellency the Royal Italian Ambassador and has the honor to refer again to the memorandum of the Chargé d’Affaires ad interim of Italy, dated August 16, 1934, in which inquiry is made with regard to the Federal and State taxation of Italian newspapermen in the United States. It is noted that the proposal is made that the Italian Government would be disposed to exempt from all income taxes American journalists now in Italy, provided a similar exemption were granted to Italian journalists residing in the United States.

The Secretary of State is not in a position to state what taxes are imposed by the several states of this country on Italian journalists. However, Italian journalists in the United States are liable to the Federal income tax. If such journalists in the United States are residents of the United States, they are liable to the tax with respect to their income from sources within and sources without the United States, while if they are nonresident aliens they are liable to the tax upon their income from sources within the United States only, including the compensation they receive for their services rendered within the United States.

There is no provision in the Revenue Act of 1934,27 the income tax law in effect at the present time, which would make it possible for the Executive branch of the Government to exempt Italian journalists in the United States from the payment of income taxes on the basis of reciprocity.

  1. 48 Stat. 680.