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In the 1930s, a significant tax dispute between the United States and France catalyzed legislative action in the American Congress. Lawmakers were increasingly frustrated with countries that appeared economically unfriendly to the United States, criticizing several nations but primarily focusing on France. These criticisms came as French authorities were slow to ratify a tax treaty, resulting in double taxation of American citizens and businesses.

By 1934, the impatience of American legislators culminated in the introduction of Section 891. This provision empowered the president to retaliate by doubling taxes on citizens and companies from countries deemed to be overtaxing Americans. Though specifically prompted by French actions, this statute was a broader demonstration of congressional resolve to protect American economic interests on the global stage.

Section 891 thus marked a significant development in U.S. tax policy, illustrating the lengths to which American lawmakers were prepared to go in order to ensure fair treatment of American businesses and individuals abroad. The legislative move was not just a response to immediate frustrations but also set a precedent for future international tax negotiations.