Editorial Note

On January 11, 1946, Mr. Frederick Livesey, Adviser, Office of Financial and Development Policy, reported to the Executive Committee on Economic Foreign Policy on the program of this Government with respect to double taxation treaties. It was explained that the purpose of these treaties was the avoidance of double taxation in income taxes and the establishment of rules of reciprocal administrative assistance in the collection of such taxes. Mr. Livesey pointed out that as of that date the United States had four tax conventions with three different countries, concerning income taxes with Sweden, France, and Canada and concerning death taxes with Canada.

During 1946 the treaty process concerning two conventions signed with the United Kingdom in April 1945 on income taxes and death duties was completed, and instruments of ratification were exchanged in Washington in July. In 1946 also a convention was negotiated ad referendum in Washington with France in March and April and signed in Paris in October; this had to do with the avoidance of double taxation with respect to taxes on estates of deceased persons and inheritances and the extension of reciprocal assistance in the prevention of fiscal evasion of such taxes and was supplementary to a 1939 convention between the United States and France regarding the avoidance of double taxation in income taxes. The French convention was submitted to the Senate by the President on January 10, 1947.

Further in 1946 a convention on income taxes was signed with the Union of South Africa, and discussions progressed with that country looking to a convention covering estate taxes. Draft treaties with the Netherlands, Belgium, and Luxembourg were being reviewed as the year ended in the interested offices of the Department, and an announcement was made on December 1 of a projected negotiation with the Philippines Republic.

The year 1946 saw not only an increase in the number of countries with whom the United States had negotiated tax conventions relating to the avoidance of double taxation in respect of income taxes, but also an extension of the principle of avoidance of double taxation to include [Page 1371] taxes relating to estates of deceased persons and inheritances. Basic to both types of convention was the provision for administrative cooperation in the prevention of tax evasion.

Relevant file collections in the Department of State’s central indexed files are found under the basic No. 811.5123 * * Double. In the case of France, for example (the country number for France being “51”), papers are found under No. 811.512351 Double. The appropriate office lot file for finding the records kept by the State Department regarding the activities of the Executive Committee on Economic Foreign Policy is Lot 122. Boxes 20–22 of this lot contain minutes and documents of the committee for this period.