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June 1, 1936

&r* C* V* Opper,
Assistant General Counsel,
Treasury Department*
Washington, D* C*
Dear &r* Opper;
Mr* Clayton showed me the proposed definition
of the term "bank" as used in the pending tax bill* Upon
consideration of the matter this definition seems to be
entirely satisfactory so far as member banks of the Federal Reserve System are concerned^ I might point out, however, that under section 19 of the Federal Reserve Act banks
organised under the laws of a dependency or insular possession of the United States are eligible for membership in
the System and while at the moment we have no such members
we have applications for membership pending, and it is possible that applications of this kind might be granted*
We are informed that the tax bill as now drawn
does not cover corporations organized under the laws of
dependencies or insular possessions, but if such corporations should be subject to tax under the bill, consideration should then
be given to a change in the definition of
the word *bank so as to include those organized under the
laws of dependencies or insular possessions*
Yours very truly,
General C o u n >rs
t s Office.



Approved by •
Revised by





Um S* Eccles,