Page:United States Statutes at Large Volume 107 Part 1.djvu/518

 107 STAT. 492 PUBLIC LAW 103-66 —AUG. 10, 1993 allowable as a deduction under this chapter to the possession corporation for such taxable year with respect to— "(i) employer contributions under a stock bonus, pension, profit-sharing, or annuity plan, accident or health plan for employees, and " (iii) the cost of life or disability insurance provided to employees. Any amount treated as wages under paragraph (I)(D) shall not be taken into account under this subparagraph. "(A) AMOUNT OF CREDIT FOR POSSESSION CORPORATIONS NOT USING PROFIT SPLIT. — "(i) IN GENERAL. —For purposes of subsection (a)(4)(A)(iii), the amount of the qualified possession income taxes for any taxable year allocable to nonsheltered income shall be an amount which bears the same ratio to the possession income taxes for such taxable year as— "(I) the increase in the tax liability of the possession corporation under this chapter for the taxable year by reason of subsection (a)(4)(A) (without regard to clause (iii) thereof), bears to "(II) the tax liability of the possession corporation under this chapter for the taxable year determined without regard to the credit allowable under this section. " (ii) LIMITATION ON AMOUNT OF TAXES TAKEN INTO ACCOUNT.— Possession income taxes shall not be taken into account under clause (i) for any taxable year to the extent that the amount of such taxes exceeds 9 percent of the amount of the taxable income for such taxable year. PROFIT SPLIT. —Notwithstanding subsection (c), if a possession corporation is not described in subsection (a)(4)(A)(iii) for the taxable year, such possession corporation shall be allowed a deduction for such taxable year in an amount which bears the same ratio to the possession income tsixes for such taxable year as— "(i) the increase in the tax liability of the possession corporation under this chapter for the taxable year by reason of subsection (a)(4)(A), bears to "(ii) the tax liability of the possession corporation under this chapter for the taxable year determined without regard to the credit allowable under this section. In determining the credit under subsection (a) and in apply- ing the preceding sentence, taxable income shall be determined without regard to the preceding sentence. "(C) POSSESSION INCOME TAXES. —For purposes of this paragraph, the term 'possession income t£uces means any taxes of a possession of the United States which are treated as not being income, war profits, or excess profits taxes paid or accrued to a possession of the United States by reason of subsection (c). "(4) DEPRECIATION RULES. —For purposes of this section—
 * (ii) employer-provided coverage under any
 * (3) TREATME^^^ OF POSSESSION TAXES. —
 * (B) DEDUCTION FOR POSSESSION CORPORATIONS USING

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