26 USC § 891 - Doubling of rates of tax on citizens and corporations of certain foreign countries

---
identifier: "/us/usc/t26/s891"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 891 - Doubling of rates of tax on citizens and corporations of certain foreign countries"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "891"
section_name: "Doubling of rates of tax on citizens and corporations of certain foreign countries"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "N"
subchapter_name: "Tax Based on Income From Sources Within or Without the United States"
part_number: "II"
part_name: "NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(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.)"
---


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

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.

---

**Source Credit**: (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.)

## Editorial Notes

### Amendments

1986— struck out reference to section 821.

1984— substituted “801” for “802”.

1959— struck out reference to section 811.

1956—Act , inserted reference to section 811.

## Statutory Notes and Related Subsidiaries

### Effective Date of 1986 Amendment

Amendment by  applicable to taxable years beginning after , see , set out as a note under .

### Effective Date of 1984 Amendment

Amendment by  applicable to taxable years beginning after , see , set out as an Effective Date note under .

### Effective Date of 1959 Amendment

Amendment by  applicable only with respect to taxable years beginning after , see , set out an Effective Date note under .

### Effective Date of 1956 Amendment

Amendment by act , applicable only to taxable years beginning after , see section 6 of act , set out as a note under .