2006 US 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
Sec. 27 - Taxes of foreign countries and possessions of the United States; possession tax credit
View MetadataPublication Title | United States Code, 2006 Edition, Title 26 - INTERNAL REVENUE CODE |
Category | Bills and Statutes |
Collection | United States Code |
SuDoc Class Number | Y 1.2/5: |
Contained Within | 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 Sec. 27 - Taxes of foreign countries and possessions of the United States; possession tax credit |
Contains | section 27 |
Date | 2006 |
Laws in Effect as of Date | January 3, 2007 |
Positive Law | No |
Disposition | standard |
Source Credit | Aug. 16, 1954, ch. 736, 68A Stat. 13, §33; Pub. L. 94-455, title X, §1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered §27, Pub. L. 98-369, div. A, title IV, §471(c), July 18, 1984, 98 Stat. 826. |
Statutes at Large References | 90 Stat. 1643 98 Stat. 826 100 Stat. 2095 |
Public Law References | Public Law 94-455, Public Law 98-369, Public Law 99-514 |
§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 creditIn 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.
(Aug. 16, 1954, ch. 736, 68A Stat. 13, §33; Pub. L. 94–455, title X, §1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered §27, Pub. L. 98–369, div. A, title IV, §471(c), July 18, 1984, 98 Stat. 826.)
Amendments1984—Pub. L. 98–369, §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 AmendmentSection 1051(i) of Pub. L. 94–455, as amended by Pub. L. 99–514, §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.”
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