The Development of International Tax Law: Franco-American Treaty on Double Taxation—Draft Convention on Allocation of Business Income
The exchange of ratifications on April 9, 1935, of the Franco-American Convention on Double Taxation by Ambassador Straus and Foreign Minister Laval calls attention to the development of a new field of law in which the United States has been participating since the post-war depression. International double taxation had existed for some time before the World War as the result of countries taxing income whether derived by non-residents from local sources or by residents from foreign sources, but it did not become a serious problem until the budgetary exigencies of the World War had caused such an increase in rates that the payment of taxes to the foreign country, as well as to the home country, resulted in taking practically all of the income from carrying on business in the two. Likewise, serious double taxation existed in the field of property and estate or inheritance taxes as the result of countries taxing property having a local situs as well as property having a foreign situs but belonging to persons domiciled within their territory.