2618 DOUBLE INCOME TAX-SHIPPING PROFITS-NOR'VAY. engaged in traffic on a Norwegian port or between Norwegian ports and from taxes on income arising from the sale of tickets for the transportation of persons out of the kingdom; provided that N or- wegian {>ersons, companies and corporations are exempt in the country m question from taxes on corresponding activities. If this be not the case, the King can decide that foreign persons, companies and corporations shall pay taxes on property and/or income on activities as mentioned. In so far as sale of tickets for transporta- tion of persons out of the kingdom is concerned, this does not apply but when the sale is effected through an agent or commissioner under the Law on Emigration of May 22, 1869, see Law of June 5, 1897, and Law No. 1 of September 16, 1921. The King will also issue regulations concerning the extent of the taxation and the assessment and collection of the taxes." The Secretary of State (IJughe8) to the Norwegian Afinister (Bryn) SIR: DEPARTMENT OF STATE, WASHINGTON, January 23, 1925. I have the honor to refer to your note of November 26, 1924, con- cerning the new taxation laws enacted in Norway on August 11, 1924, which, in you opinion, reaffirm the reciprocal exemption of income and excess and war profits taxes in Norway and the United States with regard to income derived from the operation of ships under their respective flags. It appears from the enclosures transmitted with your note that the Norwegian laws of August 11, 1924, in translatIOn, provide in part as follows: "Persons, companies and corporations belonging in a foreign country are exempt from taxes on property in and income from ship[sl engaged in traffic on a Norwegian port or between Norwegian ports and from taxes on income arising from the sale of tickets for the transportation of persons out of the kingdom; provided that Norwegian persons, companies and corporations are exempt in the country in question from taxes on corresponding activities. * * *" I have the honor to inform you that it has been held by the ap- propriate authorities of this Government that the provision of the Norwegian laws of August 11, 1924, above quoted, satisfies the equivalent exemption provision of Section 213 (b) (8) of the Revenue Act of 1924, and that, therefore, the income of a. non-resident alien or foreign corporation, which consists exclusively of earnings derived from the operation of a. ship or ships documented under the laws of Norway, is exempt from Federal income taxes imposed by the Revenue Act of 1924. Accept, Sir, the renewed assurances of my highest ('onsideration.
- MR. HELMER H. BRYN,
Minister of Norway. CHARLES E. HUGHES
