2592 DOUBLE INCOME TAX-SHIPPING PROFITS-GREAT BRITAIN. ElIective date. been decided that Great Britain satisfies the equivalent exemption provisions of Section 213 (b) (8) of the Revenue Act of 1921. Refer- ence is also made to the Act of Congress approved June 2, 1924, known as the Revenue Act of 1924, which contains the provision re- lating to taxation for 1924 and subsequent years. The provisions of Section 213 (b) (8) of the Revenue Act of 1924 are identical in terms with the corresponding section of the Revenue Act of 1921. It is therefore held that Great Britain satisfies the equivalent exemption provisions of Section 213 (b) (8) of the Revenue Act of 1924. It has also been determined that the exemption from Federal tax under this holding shall be deemed to be effective from May 1, 1923, the date stipulated by your Government as the date from which the exemption applies under British laws to the income of American citizens not resident in the United Kingdom and corporations or- ganized in the United States, derived from the operation of ships documented under the laws of the United States. Reference is also made to the last paragraph of Mr. Grew's note dated August 11, 1924, setting forth the construction to be placed upon Section 213 (b) (8). In the last paragraph of your note No. 1106 dated November 18, 1924, you stated that '~the Irish Free State in common with the other British Dominions" was not to be con- sidered as affected by the Order in Council. Accordingly the ex- emption from Federal taxation in the United States will be applied on the basis of this understanding. Accept, Excellency, the renewed assurances of my highest con- sideratIon. FRANK B. KELLOGG HIS EXCELLENCY THE RIGHT HONORABLE SIR ESME HOWARD, G.C.M.O ., K.C.B., C.V.O ., Ambassador oj Great Britain. [No. 71
