Internal Revenue Code:Sec. 78. Dividends received from certain foreign corporations by domestic corporations choosing foreign tax credit

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Location in Internal Revenue Code

     TITLE 26 - INTERNAL REVENUE CODE
      Subtitle A - Income Taxes
       CHAPTER 1 - NORMAL TAXES AND SURTAXES
        Subchapter B - Computation of Taxable Income
         PART II - ITEMS SPECIFICALLY INCLUDED IN GROSS INCOME
       

Statute

    Sec. 78. Dividends received from certain foreign corporations by
        domestic corporations choosing foreign tax credit
 
      If a domestic corporation chooses to have the benefits of subpart
    A of part III of subchapter N (relating to foreign tax credit) for
    any taxable year, an amount equal to the taxes deemed to be paid by
    such corporation under section 902(a) (relating to credit for
    corporate stockholder in foreign corporation) or under section
    960(a)(1) (relating to taxes paid by foreign corporation) for such
    taxable year shall be treated for purposes of this title (other
    than section 245) as a dividend received by such domestic
    corporation from the foreign corporation.
 

Sources

    (Added Pub. L. 87-834, Sec. 9(b), Oct. 16, 1962, 76 Stat. 1001;
    amended Pub. L. 94-455, title X, Sec. 1033(b)(1), Oct. 4, 1976, 90
    Stat. 1628.)
 

Miscellaneous

                                 AMENDMENTS
      1976 - Pub. L. 94-455 substituted ''section 902(a)'' for
    ''section 902(a)(1)'' and ''section 960(a)(1)'' for ''section
    960(a)(1)(C)''.
                      EFFECTIVE DATE OF 1976 AMENDMENT
      Amendment by Pub. L. 94-455 applicable on different dates
    depending on the date the distributions were received, see section
    1033(c) of Pub. L. 94-455, set out as a note under section 902 of
    this title.
                               EFFECTIVE DATE
      Section applicable in respect of any distribution received by a
    domestic corporation after Dec. 31, 1964, and in respect of any
    distribution received by a domestic corporation before Jan. 1,
    1965, in a taxable year of such corporation beginning after Dec.
    31, 1962, but only to the extent that such distribution is made out
    of the accumulated profits of a foreign corporation for a taxable
    year (of such foreign corporation) beginning after Dec. 31, 1962,
    see section 9(e) of Pub. L. 87-834, set out as an Effective Date of
    1962 Amendment note under section 902 of this title.
 

References

                   SECTION REFERRED TO IN OTHER SECTIONS
      This section is referred to in sections 814, 901, 902, 904, 906,
    908, 1291 of this title.