; Whereas actionable matters under section 301 of the Trade Act of 1974 include, inter alia, acts, policies, and practices of a foreign country that are unreasonable or discriminatory and burden or restrict United States commerce; Whereas an act, policy, or practice is unreasonable if the act, policy, or practice, while not necessarily in violation of, or inconsistent with, the international legal rights of the United States, is otherwise unfair and inequitable; Whereas in response to France’s DST, the United States Trade Representative (USTR) published the Report on France’s Digital Services Tax Prepared in the Investigation under Section 301 of the Trade Act of 1974 on December 2, 2019; Whereas the report made five main findings, including— (1) that the evidence collected in this investigation indicates that the French DST is intended to, and by its structure and operation does, discriminate against U.S. digital companies ; (2) that the evidence collected in this investigation indicates that the French DST’s retroactive application is unusual and inconsistent with prevailing tax principles and renders the tax particularly burdensome for covered U.S. companies, which will also affect their customers, including U.S. small businesses and consumers ; (3) that the evidence collected in this investigation indicates that the French DST’s application to gross revenue rather than income contravenes prevailing tax principles and imposes significant additional burdens on covered U.S. companies ; (4) that the evidence collected in this investigation indicates that the French DST’s application to revenues unconnected to a presence in France contravenes prevailing international tax principles and is particularly burdensome for covered U.S. companies ; and (5) that the evidence collected in this investigation indicates that the French DST’s application to a small group of digital companies contravenes international tax principles counseling against targeting the digital economy for special, unfavorable tax treatment