Internal Revenue Code:Sec. 27. Taxes of foreign countries and possessions of the United States; possession tax credit

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Contents


Location in Internal Revenue Code


     TITLE 26 - INTERNAL REVENUE CODE
      Subtitle A - Income Taxes
       CHAPTER 1 - NORMAL TAXES AND SURTAXES
        Subchapter A - Determination of Tax Liability
         PART IV - CREDITS AGAINST TAX
          Subpart B - Other Credits
        

Statute

    Sec. 27. Taxes of foreign countries and possessions of the United
        States; possession tax credit
 
    (a) Foreign tax credit
      The amount of taxes imposed by foreign countries and possessions
    of the United States shall be allowed as a credit against the tax
    imposed by this chapter to the extent provided in section 901.
    (b) Section 936 credit
      In the case of a domestic corporation, the amount provided by
    section 936 (relating to Puerto Rico and possession tax credit)
    shall be allowed as a credit against the tax imposed by this
    chapter.
 

Sources

    (Aug. 16, 1954, ch. 736, 68A Stat. 13, Sec. 33; Pub. L. 94-455,
    title X, Sec. 1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered Sec.
    27, Pub. L. 98-369, div.  A, title IV, Sec. 471(c), July 18, 1984,
    98 Stat. 826.)
 

Miscellaneous

                                 AMENDMENTS
      1984 - Pub. L. 98-369, Sec. 471(c), renumbered section 33 of this
    title as this section.
      1976 - Pub. L. 94-455 designated existing provisions as subsec.
    (a) and added subsec. (b).
                      EFFECTIVE DATE OF 1976 AMENDMENT
      Section 1051(i) of Pub. L. 94-455, as amended by Pub. L. 99-514,
    Sec. 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
      ''(1) Except as provided by paragraph (2), the amendments made by
    this section (enacting section 936 of this title and amending
    sections 33 (now 27), 48, 116, 243, 246, 861, 901, 904, 931, 1504,
    and 6091 of this title) shall apply to taxable years beginning
    after December 31, 1975, except that 'qualified possession source
    investment income' as defined in section 936(d)(2) of the Internal
    Revenue Code of 1986 (formerly I.R.C. 1954) shall include income
    from any source outside the United States if the taxpayer
    establishes to the satisfaction of the Secretary of the Treasury or
    his delegate that the income from such sources was earned before
    October 1, 1976.
      ''(2) The amendment made by subsection (d)(2) (amending section
    901 of this title) shall not apply to any tax imposed by a
    possession of the United States with respect to the complete
    liquidation occurring before January 1, 1979, of a corporation to
    the extent that such tax is attributable to earnings and profits
    accumulated by such corporation during periods ending before
    January 1, 1976.''
 

References

                   SECTION REFERRED TO IN OTHER SECTIONS
      This section is referred to in sections 23, 24, 25B, 26, 29, 30,
    55, 59, 108, 469, 691, 1351 of this title.
 

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