851.5123 Guaranty Trust Co./22

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

No. 105

Sir: I have the honor to acknowledge the receipt of the Department’s instruction No. 1504 of October 13, 1936 with which was transmitted a copy of a letter dated July 9, 1936 from the Guaranty Trust Company [Page 125] of New York71 in regard to the “Patente” tax on its capital imposed by the French Government by reason of the operation of the company’s business in France.

This case was mentioned in the general discussions which took place recently between officers of the Ministry of Finance and Mr. King, of the Treasury Department, Mr. de Wolf, of the Department of State, and Mr. Hawks of the Embassy (See Embassy’s despatch No. 96 of November 10, 1936).

In view of the fact that as the Embassy’s understanding is that Mr. King and Mr. de Wolf are going to discuss in Washington the question of whether or not the Government of the United States desires to open negotiations looking toward agreeing upon an addendum to the Franco-American double taxation convention, it was thought advisable not to address a communication to the French Government with regard to the case of the Guaranty Trust Company until after a decision had been reached in Washington with regard to the question of whether or not negotiations would be opened. Mr. King and Mr. de Wolf approved of this decision which was likewise discussed with Mr. Mitchell Carrol, Counsel for the Guaranty Trust Company, who also approves.

Respectfully yours,

For the Ambassador:
Edwin C. Wilson
  1. Letter not printed.