Page:United States Statutes at Large Volume 68A.djvu/325

 CH. 1—NORMAL TAXES AND SURTAXES

285

PART III—INCOME FROM SOURCES WITHOUT THE UNITED STATES

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Subpart Subpart Subpart Subpart Subpart

A. B. C. D. E.

Foreign tax credit. Earned income of citizens of United States. Western Hemisphere trade corporations. Possessions of the United States. China Trade Act corporations.

Subpart A—Foreign Tax Credit Sec. 901. Taxes of foreign countries and of possessions of United States. Sec. 902. Credit for corporate stockholder in foreign corporation. Sec. 903. Credit for taxes in lieu of income, etc., taxes. Sec. 904. Limitation on credit. Sec. 905. Applicable rules.

SEC. 901. TAXES OF FOREIGN COUNTRIES AND OF POSSESSIONS OF UNITED STATES. (a) ALLOWANCE o r CREDIT.—If the taxpayer chooses to have the

benefits of this subpart, the tax imposed by this chapter shall, subject to the limitation of section 904, be credited with the amounts provided in the applicable paragraph of subsection (b) plus, in the case of a corporation, the taxes deemed to have been paid under section 902. Such choice may be made or changed at any time prior to the expiration of the period prescribed for making a claim for credit or refund of the tax against which the credit is allowable. The credit shall not be allowed against the tax imposed by section 531 (relating to the tax on accumulated earnings), against the additional tax imposed for the taxable year under section 1333 (relating to war loss recoveries), or against the personal holding company tax imposed by section 541. (b) AMOUNT ALLOWED.—Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTICORPORATIONS.—In the case of a citizen of the United States and of a domestic corporation, the 'T! amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and b

(2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.—In the

- case of a resident of the United States and in the case of an individual who is a bona fide resident of Puerto Rico during the entire taxable year, the amount of any such taxes paid or accrued during the taxable year to any possession of the United States; and •J

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§ 901(b)(2)

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