811.5123/2321

The French Embassy to the Department of State

[Translation]

Aide-Mémoire

In a note of January 15, 1935, the Embassy had the honor to draw the attention of the Department of State to the unfavorable consequences to Franco-American trade involved by the application of a decision of the Treasury Department to tax, in execution of the fiscal law of 1916, the profits earned since 1929 in the United States by nonresident foreigners, and particularly French nationals.

In reply to the said communication, the Department of State was good enough to advise, under date of February 16, that the Treasury Department services were undertaking a general study of the subject of the fiscal régime of individuals and companies of foreign nationality in the United States, in connection with international trade.

In view of the proof of good will that the French Government has just given to the American Government by ratifying the instrument of the agreement of 1932 on double taxation,8 the French Embassy would attach great importance to being informed of the results of the said studies, and would be happy to know whether the Federal authorities contemplate the early adoption of measures capable of correcting the difficulties which the present situation causes to French commercial and financial establishments operating in the markets of the United States.

  1. Signed at Paris, April 27, 1932, Foreign Relations, 1932, vol. ii, p. 268.