An untested tool in President Donald Trump’s arsenal that would allow him to double taxes on foreign companies and individuals in retaliation for “discriminatory” taxes on US companies is likely to hit a legal snag if it is invoked—US double-tax treaties.
Practitioners said such treaties would take legal precedence over Section 891 of the tax code, a 1934 provision that Trump has mentioned in a few communications, including a Feb. 21 memorandum.
The treaties are formal agreements between countries that set out exemptions or reduced tax rates for resident companies to avoid having them taxed twice.
Almost all US ...
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