2586 DOUBLE INCOME TAX-SHIPPING PROFITS-SPAIN. from operation of ships documented under the laws of Spain would be exempted from taxation by the United States under those Acts. It was further stated that inasmuch as sections 212(b) and 231(b) of the Revenue Act of 1928, relating to exemption of the income of nonresident aliens and foreign corporations, are substantially the same as section 213(b)(8) of the Revenue Acts of 1921, 1924, and 1926, the exemption would be extended to the taxable years governed by the Revenue Act of 1928. "In order to put the arran~ement into effect this Department, under date of April 25, 1930, Issued Treasury Decision 4289 which amended article 89 of Regulations 62, 65, and 69, and article 1042 of Regulations 74, pertaining to the reciprocal exemption from income tax of earnings derived by nonresident aliens and foreign corporations from the operation of ships documented under the laws of foreign countries. The effect of that Treasury decision is to include Spain in the list of countries which exempt from tax so much of the income of citizens of the United States nonresident in such foreign countries and of corporations organized in the United States as consists of earnings derived from the operation of a ship or ships documented under the laws of the United States, and to exclude Spain from the list of countries which do not grant such exemption. "In addition to the formal Treasury decision issued by this Depart- ment the Collector of Internal Revenue, Customhouse, N ew York, New York, was specifically advised under date of April 23, 1930, as to the ruling contained in the letter from this Department addressed to your Department under date of March 31, 1930, and was informed that the Compania Transatlantica (Spanish Royal Mail Line) would not be held liable for income tax on income which consists exclusively of earnings derived from the operation of ships documented under the laws of Spain for the taxable years arising under the Revenue Acts of 1921, 1924, 1926, and 1928." Accept [etc.] For the Secretary of State: HIS EXCELLENCY SE&OR DON ALEJANDRO PADILLA Y BELL, Ambassador of Spain. [No.6) FRANCIS WRITE
