Who would pay America’s “revenge tax” on foreigners?

The trouble started, as it often does, with France. Congressmen in the 1930s complained about “nations throughout this world who are not particularly friendly to Uncle Sam in a business way”. Mainly that meant the European power, which had slow-walked ratification of a tax treaty and was double-taxing Americans in the meantime. In 1934, to persuade French policymakers to pick up the pace, Congress passed a provision that is now known as Section 891. It granted the president the power to double levies on citizens and companies from countries that he judged to be overtaxing Americans.