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.

The steady decline during the last half-century in the degree of effective control wielded by China over the borderlands of her great empire has been accompanied by widespread confusion concerning the international position of these areas. Obscured through the establishment by foreign nations of numerous special concessions, spheres of influence, and protectorates, the exact legal relationship existing between the central authority of China and the governors of these territories has been a cause for frequent and vigorous debate. Those groups which have sought to advance the claims of their governments to wider concessions in these regions, and those publicists who have made unsubstantiated statements about the imperialistic aims of various states in these areas, have profited by this confusion. This condition of uncertainty regarding legal status, which exists in some degree with regard to each of the four Chinese dependencies, is markedly present in the case of Outer Mongolia, a region of growing importance in Far Eastern affairs.