# 26 U.S.C. § 891: Doubling of rates of tax on citizens and corporations of certain foreign countries

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s891>. Cite pinpoints as 26 U.S.C. § 891(a)(1).

Whenever the President finds that, under the laws of any foreign country, citizens or corporations of the United States are being subjected to discriminatory or extraterritorial taxes, the President shall so proclaim and the rates of tax imposed by sections 1, 3, 11, 801, 831, 852, 871, and 881 shall, for the taxable year during which such proclamation is made and for each taxable year thereafter, be doubled in the case of each citizen and corporation of such foreign country; but the tax at such doubled rate shall be considered as imposed by such sections as the case may be. In no case shall this section operate to increase the taxes imposed by such sections (computed without regard to this section) to an amount in excess of 80 percent of the taxable income of the taxpayer (computed without regard to the deductions allowable under section 151 and under part VIII of subchapter B). Whenever the President finds that the laws of any foreign country with respect to which the President has made a proclamation under the preceding provisions of this section have been modified so that discriminatory and extraterritorial taxes applicable to citizens and corporations of the United States have been removed, he shall so proclaim, and the provisions of this section providing for doubled rates of tax shall not apply to any citizen or corporation of such foreign country with respect to any taxable year beginning after such proclamation is made.

## Regulations

- [Treas. Reg. § 1.891](/26/reg/1.891.md): Statutory provisions; doubling of rates of tax on citizens and corporations of certain foreign countries. (interprets § 891)

## Connections

Cites: § 151 Allowance of deductions for personal exemptions

Cited by: § 5 Cross references relating to tax on individuals; § 12 Cross references relating to tax on corporations; § 871 Tax on nonresident alien individuals; § 881 Tax on income of foreign corporations not connected with United States business

Derived from: 1939 § 103

## Amendments

- 1954-08-16: [Act Aug. 16, 1954, ch. 736](/26/act/1954-ch736.md), 68A Stat. 283
- 1956-03-13: [Act Mar. 13, 1956, ch. 83](/26/act/1956-ch83.md), 70 Stat. 49
- 1959-06-25: [Pub. L. 86-69](/26/act/86-69.md), 73 Stat. 140
- 1984-07-18: [Pub. L. 98-369](/26/act/98-369.md), 98 Stat. 755
- 1986-10-22: [Pub. L. 99-514](/26/act/99-514.md), 100 Stat. 2408