DOUBLE INCOME TAX-SHIPPING PROFITS-GREECE. The Minister of Greece should be exceedingly obliged if His Excel- lency the Secretary of State were kind enough to arrive at a definite decision with reference to the general question of exemption of earnings made in the United States by ships :flying the Greek :flag on the basis of reciprocity and in case that an agreement on this matter would be necessary the Minister of Greece is duly authorized to sign it. HIS EXCELLENCY MR. HENRY L. STIMSON, Secretary of State, etc., etc., n'ashington, D. C. The Secretary of State (Stimson) to the Greek ~linister (Simopoulos) DEPARTMENT OF STATE, 'WASHINGTON, June 10, 1929. 2611 The Secretary of State presents his compliments to the Minister st!~entbYUDited of Greece and has the honor to inform the Minister, with refer- ence to his note No. 422 of April 2, 1929, relative to the provisions of the Greek net income tax law whereby ships fiyin~ a foreign :flag may be exempted from taxation on the profits made ill Greece, that the Secretary of the Treasury has notified the Department of State as follows: "Inasmuch as Greece has not taxed the income of a citizen of the United States not residing in Greece and of a corporation organ- ized in the United States derived from the operation of ships :flying the American:flag from 1921 and does not tax such income under the present law, Greece satisfies the equivalent exemption provisions of section 213 (b) (8) of the Revenue Acts of 1921, 1924, and 1926 and sections 212 (b) and 231 (b) of the Revenue Act of 1928. It is held, therefore, that the income of a nonresident alien individual and a for- eign corporation from sources within the United States which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of Greece is not required to be included in gross income and is exempt from income, excess-profits and war- profits taxes for 1921 and subsequent years. If any tax on such in- come has been paid it will be refunded upon proper claims therefor being made by taxparers who are entitled to the exemption, provided the period of limitatIOn for making refunds has not expired." [No. 131
