DOUBLE INCOME TAX-IRISH FREE STATE. of the United States Revenue Act of 1932. I have pleasure in in- forming you that I am now in receipt of a letter from the Acting Secretary of the Treasury dated December 14, 1933, which reads in part as follows: " In view of the fact that the Irish Free State, under the provision of law quoted above, exempts from income tax so much of the in- come of a citizen of the Umted States not resident in the Irish Free State or of a corporation organized in the United States as is de- rived from the operation of a ship or ships documented under the laws of the United States, it is the opinion of this Department that the Irish Free State meets the reciprocal exemftion provisions of sections 212 (b) and 231 (b) of the Revenue Act 0 1932. The income of a non-resident alien individual and of a foreign corporation which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of the Irish Free State is, there- fore, not required to be included in gross income and is exempt from income tax under the provisions of the Revenue Act of 1932. The exemption accorded herein is effective April 6, 1932, the beginnhg of the first income-tax taxable year to which Section 10 of the Finance Act of 1932 is applicable." It will be observed that the Acting Secretary of the Treasury holds that in view of the fact that the Irish Free State, under the provi- sions of Section 10 of the Irish Free State Finance Act of 1932, exempts from income tax so much of the income of a citizen of the United States not resident in the Irish Free State or of a corporation organized in the United States as is derived from the operation of a ship or ships documented under the laws of the United States, the Irish Free State has satisfied the equivalent exemption provisions of Sections 212(b) and 231 (b) of the United States Revenue Act of 1932. The exemption accorded to steamship owners of the Irish Free State under the above ruling of the Acting Secretary of the Treasury is effective as of April 6, 1932, the beginning of the first income-tax taxable year to which Section 10 of the Irish Free State Finance Act of 1932 is applicable. Accept, Sir, the renewed assurances of my highest consideration. For the Acting Secretary of State: R. WALTON MOORE Mr. MICHAEL MAcWHITE, Minister of the Irish Free State. [No. 56] 1843
