CONTENTS Christian, Ernest S., Jr., Patton, Boggs & Blow, on behalf of the Com- mittee on State Taxation, Council of State Chambers of Commerce, Cory, Kenneth, controller, State of California, Sacramento, Calif. De Looze, Theodore W., chief tax counsel, Oregon Department of Denebeim, Bruce E., senior vice president, the Chartered Bank of Lon- Gallagher, Sterling, commissioner, department of revenue, State of Gotelli, Andrew W., Peat, Marwick, Mitchell & Company, on behalf Hayakawa, Hon. S. I., a U.S. Senator from California.... Kurtz, Hon. Jerome, Commissioner, Internal Revenue Service; ac- companied by Stuart Seigel, Chief Counsel, Internal Revenue Lobdell, John J., director of revenue, State of Oregon; immediate past chairman of the board of trustees of the Federation of Tax Admin- istrators; and present chairman of the Multi-State Tax Commission, 90 149 295 146 236 291 McKee, William D., on behalf of the Committee of Foreign Banks in Nolan, John S., Miller & Chevalier, on behalf of the British National Committee of the International Chamber of Commerce and the Con- federation of British Industry, Washington, D.C__. Norris, Robert M., president, National Trade Council, New York, 184 Osterhuis, Paul J., legislation counsel, Joint Committee on Taxation; accompanied by David Brockway, legislation attorney, Joint Com- Philion, Norman J., executive vice president, Air Transport Association 56 Reveal, Ernest I., president, R. T. French Co., Rochester, N.Y. 206 63 Walker, Charles M., former Assistant Secretary of the Treasury for 221 Woodworth, Laurence N., Assistant Secretary for Tax Policy, Depart- 48, 82 Insertions for the record: Letter to Senator Frank Church from Laurence N. Woodworth, De- Page partment of the Treasury, dated July 18, 1977- Letter to Senator John Sparkman from Representative Al Ullman, dated July 18, 1977. Letter to United Kingdom Petroleum Revenue Tax, Frederic W. Hick- Prepared statement of Assistant Secretary of the Treasury Laurence Prepared statement of Paul Oosterhuis, legislation counsel, and David Prepared statement of the National Association of Tax Administra- Prepared statement of John J. Lobdell, director of revenue, State of Prepared statement of Assistant Secretary of the Treasury Laurence 2 State of California Franchise Tax Board, United States-United Kingdom Treaty Position Paper-- Prepared statement of Sterling Gallagher, commissioner of revenue, Multistate Tax Commission Resolution No. 2-Opposing Federal restrictions on State taxing powers and methods.. Supreme Court of Montana decision in Montana Department of Revenue, State of Montana, Petitioner and Appellant, v. The American Smelting and Refining Co., Defendant and Respondent, No. 13249, 1977 Prepared statement of Oregon Department of Revenue, presented by Prepared statement of Ernest S. Christian, Jr., on behalf of Committee 152 159 174 181 Prepared statement of John S. Nolan, on behalf of the British National Committee of the International Chamber of Commerce and the Confederation of British Industry 188 Prepared statement of Ernest I. Reveal, president, R. T. French Co., and attachment_-_. 209 Position paper of Valentine Brookes, Esq., on proposed United StatesUnited Kingdom Income Tax Convention, particular reference to limitation of the power of the States to tax 215 Extension of testimony of Valentine Brookes, Esq-- 219 Prepared statement of Charles M. Walker, former Assistant Secretary of the Treasury for Tax Policy---. 225 Supplemental letter to Senator John Sparkman from Charles M. 232 Corporations represented on the California Council for International 236 243 Prepared statement of Paul S. Berger, general counsel, Screen Actors 249 Prepared statement of Bruce K. Denebeim_ 298 Memorandum on issues raised in testimony before the Senate Committee on Foreign Relations in connection with the proposed Income Tax Treaty with the United Kingdom, supplied by the Department of Treasury-. 303 Letter to Senator Frank Church from Kenneth Cory, controller of the 312 Appendix: Technical explanation of the Convention Between the Government Memorandum to the Senate Foreign Relations Committee from Harry Page 317 318 350 375 378 381 Text of telegram to Senator John Sparkman from Hon. Edmund G. 399 Letter to Senator James A. McClure from Hon. John V. Evans, Governor of Idaho, dated May 2, 1977___ 399 Letter to Senator James A. McClure from Hon. Cecil D. Andrus, 401 Statement of Arthur C. Roemer, commissioner of revenue, State of 402 Letter to Senator John Sparkman from Hon. Ray Blanton, Governor of Tennessee, dated June 21, 1977--- Letter to Senator John Sparkman from Senator Patrick J. Leary, 403 404 404 Prepared statement of Marry Ellen McCaffree, Washington Director of Revenue 405 Letter to Senator Robert C. Byrd from Hon. John D. Rockefeller IV, 407 Letter to Senator Robert C. Byrd from Richard L. Dailey, State tax 408 409 "Brown [Governor] Defends Stand," article from the Wall Street Journal, July 12, 1977--- 411 Letter to Mr. Martin Huff, exectuive officer, California Franchise Tax Statement submitted by the Committee on State Taxation, Council of Statement submitted on behalf of the Barclays Bank of California___ Letter from I. E. Zacher, director, corporate taxes and insurance, 412 412 414 424 427 Letter to Senator John Sparkman from Edward T. Mitchell, Patton, Boggs & Blow, dated August 3, 1977, enclosing statement of Robert Page C. Lee, president, Bellefonte Insurance Co_____ Statement of the National Association of Manufacturers___ Letter to Senator John Sparkman from W. K. Woodson, tax manager, Getty Oil Co., dated July 20, 1977, enclosing statement submitted on behalf of Dart Industries, Inc., the Fluor Corp., Getty Oil Co., Santa Fe International Corp., Security Pacific National Bank, Twentieth Century-Fox Film Corp., and Union Oil Co‒‒‒‒‒ Letter to Senator John Sparkman from Edward Cameron III, dated July 19, 1977, enclosing brief submitted on behalf of AA Mutual Insurance Association, Ltd., British National Life Insurance So- ciety, Ltd., La Condorde Campagnie D'Assurance S.A., Mentor In- surance Co. (U.K.), Ltd., Minister Insurance Co., Ltd., Overseas Insurance, Ltd., "The Phoenix” Greek General Insurance Co., Scot- tish Lion Insurance Co., Ltd., and the Sumitomo Marine & Fire In- Letter to Senator John Sparkman from Gerald M. Lowrie, executive director, governmental relations, American Bankers Association, Letter to Senator Sparkman from William J. Nolan, Jr., chairman, committee on taxation, U.S. Council of the International Chamber Statement of Ronald L. Danielian, executive vice president and treas- urer, International Economic Policy Association__ Letter to Senator Frank Church from President Jimmy Carter, dated Letter to Senator John Sparkman from Norman J. Philion, Air Trans- port Association of America, dated August 2, 1977, enclosing text of telegrams submitted to Laurence N. Woodworth, Assistant Secre- tary for Tax Policy, Department of the Treasury, and summary Letter to Senator John Sparkman from Richard M. Hammer, president, U.S.A. Branch, International Fiscal Association, Inc., dated July 28, Statement by Emergency Committee for American Trade_ Statement of the National Foreign Trade Council, Inc-- Letter to Senator John Sparkman from Charles Stewart, president, Machinery and Allied Products Institute, dated July 11, 1977----- Letter to Mr. Martin Huff, Executive Officer, California Franchise Tax Board, from Hon. W. Michael Blumenthal, Secretary of the Treas- Letter to Senator Jacob Javits from W. K. Woodson, corporate tax Resolution unanimously adopted at the 45th annual meeting of the Na- tional Association of Tax Administrators, held in Williamsburg, Va., Exchange of correspondence between Senator Frank Church and the Honorable Jerome Kurtz, Commissioner of Internal Revenue, in Oc- tober 1977, concerning IRS review of OPEC tax rulings. Letter to John Sparkman from Kenneth Cory, controller of the State all economic impact of United States-United Kingdom Tax Treaty 490 |