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civil aircraft. The term “ civil aircraft” shall be understood to mean aircraft used for private, industrial, commercial or transport purposes.

ARTICLE 2. (a) The Department of Defence of the Union of South Africa will issue pilots' licenses to American nationals upon a showing that they are qualified under the regulations of that Department covering the licensing of pilots.

(6) The Department of Commerce of the United States of America will issue pilots' licenses to nationals of the Union of South Africa upon a showing that they are qualified under the regulations of that Department covering the licensing of pilots.

ARTICLE 3. (a) Pilots' licenses issued by the Department of Commerce of the United States of America to nationals of the Union of South Africa shall entitle them to the same privileges as are granted by pilots licenses issued to American nationals.

(6) Pilots' licenses issued by the Department of Defence of the Union of South Africa to American nationals shall entitle them to the same privileges as are granted by pilots' licenses issued to nationals of the Union of South Africa.

1

ARTICLE 4. Pilots' licenses issued to nationals of the one country by the competent authority of the other country shall not be construed to accord to the licensees the right to register aircraft in such other country.

ARTICLE 5. Pilots' licenses issued to nationals of the one country by the competent authority of the other country shall not be construed to accord to the licensees the right to operate aircraft in air commerce wholly within territory of such other country reserved to national aircraft, unless the aircraft have been registered under the laws of the country issuing the pilots' licenses.

ARTICLE 6.

(a) Nationals of the Union of South Africa shall while holding valid pilot licenses issued by the Department of Defence of the Union of South Africa be permitted to operate in Continental United States of America, exclusive of Alaska, for non-industrial or non-commercial purposes for a period not exceeding six months from the time of entering that country, any civil aircraft registered by the Department of Defence of the Union of South Africa, and/or any civil aircraft registered by the United States Department of Commerce. The period of validity of the licenses first mentioned in this paragraph shall, for the purpose of this paragraph, include any renewal of the license by the pilot's own Government made after the pilot has entered Continental United States of America. No person to whom this paragraph applies shall be allowed to operate civil aircraft in Continental United States of America, exclusive of Alaska, for non-industrial or non-commercial purposes for a period of more than six months from the time of entering that country, unless he shall, prior to the expiration of such period, have obtained a pilot license from the United States Department of Commerce in the manner provided for in this arrangement.

(6) American nationals shall while holding valid pilot licenses issued by the United States Department of Commerce be permitted to operate in the Union of South Africa for non-industrial or noncommercial purposes for a period not exceeding six months from the time of entering that country, any civil aircraft registered by the United States Department of Commerce, and/or any civil aircraft registered by the Department of Defence of the Union of South Africa. The period of validity of the licenses first mentioned in this paragraph shall, for the purpose of this paragraph, include any renewal of the license by the pilot's own Government made after the pilot has entered the Union of South Africa. No person to whom this paragraph applies shall be allowed to operate civil aircraft in the Union of South Africa for non-industrial or non-commercial purposes for a period of more than six months from the time of entering that country, unless he shall, prior to the expiration of such period, have obtained a pilot's license from the Department of Defence of the Union of South Africa in the manner provided for in this arrangement.

(c) The conditions under which pilots of the nationality of either country may operate aircraft of their country in the other country, as provided for in this article, shall be as stipulated in the air navigation arrangement in force between the parties to this arrangement for the issuance of pilot licenses; and the conditions under which pilots of the nationality of either country may operate aircraft of the other country, as provided for in this article, shall be in accordance with the requirements of such other country.

ARTICLE 7. The present arrangement shall be subject to termination by either Party upon sixty days' notice given to the other Party or by the enactment by either Party of legislation inconsistent therewith."

It is further agreed that the arrangement will be operative as from the date of this note. I have the honour to be, Sir, Your obedient Servant,

J. B. M. HERTZOG.

Minister of External Affairs. The ENVOY EXTRAORDINARY AND MINISTER PLENIPOTENTIARY OF THE UNITED STATES OF AMERICA,

Pretoria.

[No. 55]

August 24, 1933.
January 9, 1934.

Arrangement between the United States of America and the Irish Free

State, providing relief from double income tax on shipping profits. Effected by exchange of notes, signed August 24, 1933, and January 9, 1934.

The Chargé d'Affaires ad interim of the Irish Free State (Macaulay)

to the Secretary of State

States and Irish Free State.

IRISH FREE STATE LEGATION,

Washington, D.C., 24th August, 1933. SIR: Double income tax on shipping profits.

I am requested by my Government to bring to the notice of the Reciprocal exemp. Government of the United States the provisions of Section 10 of

the Finance Act, 1932 (No. 20 of 1932) which section reads as follows:

“10.—Subject to the provisions of this section, exemption shall be granted from income tax (including super-tax, or sur-tax, as the case may be) in respect of so much of the income of a citizen of the United States of America not resident in the Irish Free State or of a corporation organised in the United States of America as is derived from the operation of a ship or ships documented under the laws of the United States of America." I have the honour to be, Sir, Your obedient servant,

WJB MACAULAY

Chargé d'Affaires ad interim
Honourable CORDELL HULL
The Secretary of State of the United States

Washington, D.C.

Agreement United States.

The Acting Secretary of State to the Minister of the Irish Free State

(MacWhite)

DEPARTMENT OF STATE,

Washington, January 9, 1934. SIR: by

In a note dated August 24, 1933, Mr. Macaulay, as Chargé d'Affaires ad interim, brought to the notice of the Government of the United States the provisions of Section 10 of the Irish Free State Finance Act of 1932, which provides for the relief of American steamship owners from double income tax on shipping profits.

The text of Section 10 of the above law was brought to the atten

tion of the Secretary of the Treasury, with the request that he inform Vol. 47, pp. 228, 230. the Department of State whether the Irish Free State satisfied the

equivalent exemption requirements of Sections 212(b) and 231(8) of the United States Revenue Act of 1932. I have pleasure in informing 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 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, it is the opinion of this Department that the Irish Free State meets the reciprocal exemption provisions of sections 212(6) and 231(6) of the Revenue Act of 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, therefore, 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 beginning 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 provisions 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() and 231() 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 MAOWHITE,

Minister of the Irish Free State.

[No. 56]

April 24, 1934.

Protocol between the United States of America and Mexico relative to

general claims. Signed April 24, 1934; effective April 24, 1934.

Protocol with Mer. PROTOCOL RELATIVE TO CLAIMS PRE-
ico relative to General
Claims Commission.

SENTED TO THE GENERAL CLAIMS
COMMISSION,
ESTABLISHED

BY
THE CONVENTION OF SEPTEMBER
8, 1923.

PROTOCOLO RELATIVO A LAS RECLA

MACIONES PRESENTADAS ANTE LA
COMISION GENERAL DE RECLAMA-
CIONES CREADA POR LA CONVEN-
CION DE 8 DE SEPTIEMBRE DE 1923.

Plenipotentiaries.

Josephus Daniels, Ambassador Josephus Daniels, Embajador Extraordinary and Plenipoten- Extraordinario y Plenipotenciatiary of the United States of rio de los Estados Unidos de America to the Government of América ante el Gobierno de Mexico, and José Manuel Puig México, y José Manuel Puig CaCasauranc, Secretary for Foreign sauranc, Secretario de Relaciones Affairs of the United Mexican Exteriores de los Estados Unidos States, duly authorized, have Mexicanos, debidamente autoriagreed on behalf of their two zados, convienen en firmar, en Governments to conclude the fol- nombre de sus respectivos Gobierlowing Protocol:

nos, el siguiente Protocolo: Whereas, It is the desire of Considerando que es el deseo the two Governments to settle de ambos Gobiernos arreglar y and liquidate as promptly as pos- liquidar, tan pronto como sea sible those claims of each Govern- posible, las reclamaciones de cada ment against the other which are uno de los dos Gobiernos en concomprehended by, and which tra del otro, comprendidas en la have been filed in pursuance of, Convención General de Reclamathe General Claims Convention ciones celebrada el 8 de septiembetween the two Governments, bre de 1923 entre los dos Gobierconcluded on September 8, 1923; nos y registradas de acuerdo con

la misma; Whereas, It is not considered Considerando que no se juzga expedient to proceed, at the pres- viable, en los momentos actuales, ent time, to the formal arbitra- proceder al arbitraje formal de tion of the said claims in the dichas reclamaciones mediante el manner provided in that Con- procedimiento que establece la vention;

Convención mencionada; Whereas, It is considered to be Considerando que se juzga conconducive to the best interests of ducente para los mejores intethe two Governments, to preserve reses de ambos Gobiernos conserthe status quo of the General var el statu quo " de la ConvenClaims Convention above men- ción General de Reclamaciones

Vol. 43, p. 1730.

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