A-80818, OCTOBER 6, 1936, 16 COMP. GEN. 343

A-80818: Oct 6, 1936

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EXCHANGE - LOSS BY - ITALIAN LIRE IN VIEW OF THE RESTRICTIVE CONDITIONS UNDER WHICH THE TOURIST LIRE ARE ISSUED IN ITALY. EXCEPT IN THOSE CASES WHERE A SHOWING OF CONVERSION IS REQUIRED AND THE EVIDENCE SUBMITTED ESTABLISHES A CONVERSION INTO THE TOURIST LIRE RATHER THAN INTO THE REGULAR LIRE. AS FOLLOWS: I HAVE THE HONOR TO BRING TO THE ATTENTION OF THE DEPARTMENT THE SITUATION WHICH HAS ARISEN AS THE RESULT OF THE ISSUING BY THE ITALIAN GOVERNMENT OF THE SO-CALLED TOURIST LIRE. THESE LIRE ARE ISSUED IN THE FORM OF LETTERS OF CREDIT AND TRAVELLERS CHECKS. ARE NOT AVAILABLE IN QUANTITIES IN EXCESS OF 250 LIRE PER DAY PER PERSON. WHICH IS THEN EMPOWERED TO MAIL THEM TO ITALY TO THE TOURIST.

A-80818, OCTOBER 6, 1936, 16 COMP. GEN. 343

EXCHANGE - LOSS BY - ITALIAN LIRE IN VIEW OF THE RESTRICTIVE CONDITIONS UNDER WHICH THE TOURIST LIRE ARE ISSUED IN ITALY, THEIR USE SHOULD NOT BE INSISTED UPON, AND EXCHANGE RELIEF SHOULD BE COMPUTED UPON THE RATES APPLICABLE TO THE REGULAR LIRE, EXCEPT IN THOSE CASES WHERE A SHOWING OF CONVERSION IS REQUIRED AND THE EVIDENCE SUBMITTED ESTABLISHES A CONVERSION INTO THE TOURIST LIRE RATHER THAN INTO THE REGULAR LIRE.

ACTING COMPTROLLER GENERAL ELLIOTT TO THE SECRETARY OF STATE, OCTOBER 6, 1936:

THERE HAS BEEN RECEIVED YOUR LETTER OF SEPTEMBER 28, 1936, REQUESTING DECISION UPON THE QUESTION PRESENTED IN THE INCLOSED COPY OF THE DESPATCH, DATED SEPTEMBER 14, 1936, FROM THE DISTRICT ACCOUNTING AND DISBURSING OFFICER AT PARIS, FRANCE, AS FOLLOWS:

I HAVE THE HONOR TO BRING TO THE ATTENTION OF THE DEPARTMENT THE SITUATION WHICH HAS ARISEN AS THE RESULT OF THE ISSUING BY THE ITALIAN GOVERNMENT OF THE SO-CALLED TOURIST LIRE.

THESE LIRE ARE ISSUED IN THE FORM OF LETTERS OF CREDIT AND TRAVELLERS CHECKS. THEY CAN ONLY BE CASHED AT CERTAIN BANKS, HOWEVER, AND ARE NOT AVAILABLE IN QUANTITIES IN EXCESS OF 250 LIRE PER DAY PER PERSON, ALTHOUGH THEY MAY BE DRAWN IN SUMS OF 1,250 PER PERSON, BUT NOT OFTENER IN THIS CASE THAN ONCE IN FIVE DAYS.

THEY PRESENT CERTAIN IMPORTANT DIFFERENCES FROM THE GERMAN REGISTERED MARKS, HOWEVER, IN THAT THEY CAN BE OBTAINED IN ITALY BY WRITING ABROAD TO SOME ISSUING AUTHORITY, WHICH IS THEN EMPOWERED TO MAIL THEM TO ITALY TO THE TOURIST. ADDITIONAL QUANTITIES MAY ALSO BE ISSUED IN ITALY ITSELF TO ANY TOURIST IN POSSESSION OF A TOURIST LETTER OF CREDIT NOT MORE THAN SIX MONTHS OLD.

THIS WOULD THEORETICALLY PERMIT THE CONVERSION OF SALARY CHECKS INTO TOURIST LIRE, WHICH IS NOT POSSIBLE IN GERMANY, THUS AFFORDING REASONABLE GROUNDS FOR THE USE OF THIS RATE FOR THE COMPUTATION OF CURRENCY APPRECIATION LOSS ON SALARIES.

THE TOURIST LIRE ARE NOT, HOWEVER, AVAILABLE LEGALLY TO PERSONS RESIDING IN ITALY OR TO THOSE VISITING ITALY ON BUSINESS, OR OTHERWISE THAN AS MERE TOURISTS. RECIPIENTS ARE OBLIGED TO SIGN A STATEMENT TO THE EFFECT THAT THEY ARE TOURISTS. THIS RESTRICTION IS APPARENTLY AT THE MOMENT LAXLY ENFORCED AND FREQUENTLY IGNORED, BUT THIS OFFICE DOES NOT FEEL IN A POSITION TO INSIST THAT THOSE VISITING ITALY ON OFFICIAL BUSINESS USE THE TOURIST LIRE WHICH INVOLVES SIGNING KNOWINGLY A FALSE STATEMENT, AS IT WOULD BE MOST EMBARRASSING IF THE AUTHORITIES SHOULD ON SOME OCCASION DECIDE TO ENFORCE THE LAW AGAINST SOME PARTICULAR EMPLOYEE OF THE AMERICAN GOVERNMENT.

IT MAY BE POINTED OUT THAT THIS LAXITY IN ISSUING THE TOURIST LIRE OFFERS A TEMPTATION TO USE THEM IN TECHNICALLY ILLEGAL CASES AND THE OPPORTUNITY FOR ABUSE IS OBVIOUS. AN AUTHORITATIVE DECISION IS NECESSARY.

THE CASE OF THOSE VISITING ITALY ON OFFICIAL BUSINESS BUT WITHOUT ANY DEFINITE PLACE OF ASSIGNMENT ABROAD ALSO RAISES THE SAME QUESTION AS TO WHICH TYPE OF LIRE SHALL BE INSISTED ON FOR THEIR EXPENSES, PER DIEM AND SALARY.

THE QUESTION OF THE RATE TO BE USED FOR THE SALARY PAYMENTS OF THOSE TEMPORARILY IN ITALY ON OFFICIAL BUSINESS ON THE LAST DAY OF THE MONTH HAS ALSO BEEN RAISED.

A FURTHER POINT ON WHICH UNCERTAINTY EXISTS IS THE USE OF THE TOURIST LIRE RATE IN COMPUTING THE CURRENCY APPRECIATION LOSS FOR THOSE VISITING ITALY ON LEAVE OF ABSENCE. UNDER THE RULING OF THE COMPTROLLER GENERAL (VOL. 14, P. 577), IT IS NECESSARY TO TAKE THE LEAST FAVORABLE RATE OF EXCHANGE. IF THE NORMAL EXCHANGE RATE IS TAKEN, ITALY RANKS AMONG THE MORE FAVORABLE COUNTRIES, AND THOSE ON LEAVE IN MANY CASES WOULD NOT BE OBLIGED TO PRORATE. IF THE TOURIST LIRE IS TO BE USED IT WILL BE NECESSARY TO PRORATE IN NEARLY ALL CASES.

IT IS RESPECTFULLY REQUESTED THAT THE SITUATION BE PLACED BEFORE THE COMPTROLLER GENERAL AND THE POLICY TO BE FOLLOWED IN HANDLING THE TOURIST LIRE BE ESTABLISHED WITHOUT DELAY.

IN VIEW OF THE RESTRICTIVE CONDITIONS UNDER WHICH THE TOURIST LIRE A REISSUED IN ITALY, THEIR USE SHOULD NOT BE INSISTED UPON AND EXCHANGE RELIEF SHOULD BE COMPUTED UPON THE RATES APPLICABLE TO THE REGULAR LIRE, EXCEPT IN THOSE CASES WHERE A SHOWING OF CONVERSION IS REQUIRED AND THE EVIDENCE SUBMITTED ESTABLISHES A CONVERSION INTO THE TOURIST LIRE RATHER THAN REGULAR LIRE.