811.512351 Double/302

The Secretary of State to the Ambassador in France (Straus)

No. 1257

Sir: The Department refers to its instruction No. 1142 of December 19, 1936 [1935],39 relating to the desire of the French Government to conclude an addendum to the Double Taxation Convention of April 27, 1932, and encloses for your information a copy of a letter of March 23, 1936,40 received from the Treasury Department, which is believed to be self-explanatory. The Department also encloses a copy of its reply41 to that letter. You will recall that in the Department’s instruction of December 19, it was stated “that it would be helpful in considering the proposed addendum to have information concerning any loss of revenue which might be suffered by the French Government as the result of its proposed undertaking not to impose taxes on the income derived from sources in France by American citizens residing in the United States”. The Department presumes that the French authorities have not so far furnished you with this information.

The French authorities do not appear to be pressing very much the question of an addendum to the Convention and the Department will be interested in receiving an expression of your views as to whether the French Foreign Office is much concerned in this matter or whether it merely made the proposal to clear its position insofar as the Ministry of Finance was concerned.

Very truly yours,

For the Secretary of State:
R. Walton Moore
  1. Foreign Relations, 1935, vol. ii, p. 253.
  2. Not printed; the Acting Secretary of the Treasury stated that, in view of the effect which legislation pending in Congress might have on the issue of taxation of non-resident aliens, the Treasury Department “is unable, at this time, to reach a decision with respect to the advisability of entering the proposed addendum to the Double Taxation Convention.…”
  3. Not printed; the Secretary of State requested that, if necessary, the Treasury representatives who were participating in discussions for the new legislation should “take steps to safeguard the treaty.”