102.8102 Taxation/7 / France
The Ambassador in France (Herrick) to the Secretary of State
[Received June 4.]
Sir: I have the honor to refer to the Department’s telegraphic instruction No. 142 of May 19 and to my answering telegram No. 130 of May 23, 1928.13 A note based on the Department’s said instruction was personally delivered to the competent official at the Foreign Office and the question argued at length. This official was disposed to suggest, as an easy solution, that the Embassy add the names of the three Trade Commissioners to its list of officials accredited to the Foreign [Page 1003] Office. As the Embassy understands that the Department has no desire that this be done (see its telegraphic instruction No. 86 of April 8, 192614), the reply was made that this was not the point at issue, which was the imposition upon officials of the United States Government of income, personal and local taxes.
Over and above this, the Foreign Office official was inclined—as stated in my telegram—to feel that there was a distinction between the three Trade Commissioners and the customs representative, Mr. O’Neill, on the ground principally that the three former are engaged in work which is to the mutual benefit of the French and American Governments, whereas the latter is not. No acquiescence was made to this contention, and I have no idea that the Finance Ministry will accord any weight to it either.
The Foreign Office promised to transmit the question, particularly as regards the three Trade Commissioners, to the Finance Ministry with a favorable recommendation; but as a matter of fact, I see no reason to believe that this Ministry will abandon the definite and uncompromising attitude already adopted by it in this very question (see enclosure No. 2 to the Embassy’s despatch No. 5382 of July 10, 1925, as well as the Department’s telegraphic instruction No. 86 of April 8, 1926, and the Embassy’s answering telegram No. 140 of April 9, 192615). It should be noted in the present phase of the question (i.e. Department’s telegraphic instruction No. 142 of May 19, 1928) that objection is made to the assessment by the French authorities of income, personal and local taxes, whereas the argument on our side only covers the exemption from the payment of the Federal income tax accorded to officials of foreign countries in the United States. For use in future conversations, I should be glad if the Department could inform me of any further exemption accorded to such foreign officials with respect to personal and local taxes. In this connection, it may be pointed out that with respect to Trade Commissioners and Assistant Trade Commissioners, this Embassy requested similar information of the Department by despatch No. 5742 of November 20, 1925,14 but that no reply has been received.
I have [etc.]