Page:United States Statutes at Large Volume 68A.djvu/419

 CH. 11—ESTATE TAX

379

(B) subjected to such tax, and (C) included in the gross estate bears to the value of all property subjected to such tax; and (2) shall not, with respect to all such taxes, exceed an amount which bears the same ratio to the tax imposed by section 2001 (after deducting from such tax the credits provided by sections 2011 and 2012) as the value of property which is— (A) situated within such foreign country, (B) subjected to the taxes of such foreign country, and (C) included in the gross estate bears to the value of the entire gross estate reduced by the aggregate amount of the deductions allowed under sections 2055 and 2056. (c) VALUATION OF PROPERTY,—

(1) The values referred to in the ratio stated in subsection (b)(1) are the values determined for purposes of the tax imposed by such foreign country. (2) The values referred to in the ratio stated in subsection (b)(2) are the values determined under this chapter; but, in applying such ratio, the value of any property described in subparagraphs (A), (B), and (C) thereof shall be reduced by such amount as will properly reflect, in accordance with regulations prescribed by the Secretary or his delegate, the deductions allowed in respect of such property under sections 2055 and 2056 (relating to charitable and marital deductions). (d) PROOF OF C R E D I T. — The credit provided in this section shall be allowed only if the taxpayer establishes to the satisfaction of the Secretary or his delegate — (1) the amount of taxes actually paid to the foreign country, (2) the amount and date of each payment thereof, (3) the description and value of the property in respect of which such taxes are imposed, and (4) all other information necessary for the verification and computation of the credit. (e) PERIOD OF LIMITATION.—The credit provided in this section shall be allowed only for such taxes as were actually paid and credit therefor claimed within 4 years after the filing of the return required by section 6018, except that— (1) If a petition for redetermination of a deficiency has been filed with the Tax Court within the time prescribed in section 6213(a), then within such 4-year period or before the expiration of 60 days after the decision of the Tax Court becomes final. (2) If, under section 6161, an extension of time has been granted for payment of the tax shown on the return, or of a deficiency, then within such 4-year period or before the date of the expiration of the period of the extension. Refund based on such credit may (despite the provisions of sections 6511 and 6512) be made if claim therefor is filed within the period above provided. Any such refund shall be made without interest. SEC. 2015. CREDIT FOR DEATH TAXES ON REMAINDERS.

Where an election is made under section 6163(a) to postpone payment of the tax imposed by section 2001 or 2101, such part of any estate, inheritance, legacy, or succession taxes allowable as a credit §2015

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