§ 891. Doubling of rates of tax on citizens and corporations of certain foreign countries

Statutory text

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.

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

1954
Aug. 16, 1954, ch. 736, 68A Stat. 283 · 68A Stat. 283
Enacted · 26 U.S.C. § 891
Aug. 16, 1954, ch. 736, 68A Stat. 283
Source evidence
Code source credit
Aug. 16, 1954, ch. 736, 68A Stat. 283
1959
Life Insurance Company Income Tax Act of 1959
Pub. L. 86–69 § 3(f)(1) · 73 Stat. 112
Struck · 26 U.S.C. § 891
Pub. L. 86–69 struck out reference to section 811
Source evidence
Code amendment note
Pub. L. 86–69 struck out reference to section 811.
Enacted provision · exact public law section
(1) Sections 842 and 1504(b)(2) of such Code are each 26 USC 842, 1504, 891. amended by striking out “, 811,”. Section 891 of such Code is amended by striking out “811,”.
1984
Tax Reform Act of 1984
Pub. L. 98–369 div. A title II § 211(b)(12) · 98 Stat. 494
Substituted · 26 U.S.C. § 891
Pub. L. 98–369 substituted “801” for “802”
Source evidence
Code amendment note
Pub. L. 98–369 substituted “801” for “802”.
Enacted provision · exact public law section
(12) Section 891 (relating to doubling of rates of tax on citizens 26 USC 891. and corporations of certain foreign countries) is amended by striking out “802” and inserting in lieu thereof “801”.
1986
Tax Reform Act of 1986
Pub. L. 99–514 title X § 1024(c)(13) · 100 Stat. 2085
Struck · 26 U.S.C. § 891
Pub. L. 99–514 struck out reference to section 821
Source evidence
Code amendment note
Pub. L. 99–514 struck out reference to section 821.
Enacted provision · exact public law section
(13) Section 891 is amended by striking out “821,”.
Effective date note
Amendment by Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, see section 1024(e) of Pub. L. 99–514, set out as a note under section 831 of this title.

3 of 4 references resolved to an enrolled provision · 1 partial

Editorial Notes

Amendments1956–1986 · 4 rounds

1986

Pub. L. 99–514 struck out reference to section 821.

1984

Pub. L. 98–369 substituted “801” for “802”.

1959

Pub. L. 86–69 struck out reference to section 811.

1956

Act Mar. 13, 1956, inserted reference to section 811.

Statutory Notes and Related Subsidiaries

Effective Date of 1986 Amendment

Amendment by Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, see section 1024(e) of Pub. L. 99–514, set out as a note under section 831 of this title.

Effective Date of 1984 Amendment

Amendment by Pub. L. 98–369 applicable to taxable years beginning after Dec. 31, 1983, see section 215 of Pub. L. 98–369, set out as an Effective Date note under section 801 of this title.

Effective Date of 1959 Amendment

Amendment by Pub. L. 86–69 applicable only with respect to taxable years beginning after Dec. 31, 1957, see section 4 of Pub. L. 86–69, set out an Effective Date note under section 381 of this title.

Effective Date of 1956 Amendment

Amendment by act Mar. 13, 1956, applicable only to taxable years beginning after Dec. 31, 1954, see section 6 of act Mar. 13, 1956, set out as a note under section 316 of this title.

Credits

1954–1986 · 5 acts

1954Aug. 16, 1954, ch. 736, 68A Stat. 283
1956Mar. 13, 1956, ch. 83, § 5(6), 70 Stat. 49
1959Pub. L. 86–69, § 3(f)(1), June 25, 1959, 73 Stat. 140
1984Pub. L. 98–369, div. A, title II, § 211(b)(12), July 18, 1984, 98 Stat. 755
1986Pub. L. 99–514, title X, § 1024(c)(13), Oct. 22, 1986, 100 Stat. 2408.

Show as published

(Aug. 16, 1954, ch. 736, 68A Stat. 283; Mar. 13, 1956, ch. 83, § 5(6), 70 Stat. 49; Pub. L. 86–69, § 3(f)(1), June 25, 1959, 73 Stat. 140; Pub. L. 98–369, div. A, title II, § 211(b)(12), July 18, 1984, 98 Stat. 755; Pub. L. 99–514, title X, § 1024(c)(13), Oct. 22, 1986, 100 Stat. 2408.)