Page:United States Statutes at Large Volume 72 Part 1.djvu/1717

 72 8TAT.]

PUBLIC LAW 86-866-8EPT. 2, 1968

(3) Section 2053(d)(1) (relating to the deduction for estate, inheritance, legacy, or succession taxes paid in respect of a transfer for public, charitable, or religious uses) is amended by striking out "or any possession of the United States,". (4) The tsE^e of sections for subchapter C of chapter 11 is amended by adding at the end thereof the following:

1675 26 USC 2053.

"Sec. 2208. Certain residents of possessions considered citizens of the United States." (d) EFFECTIVE DATE.—The amendments made by this section (other

than by subsection (b)) shall apply to the estates of decedents dying after the date of the enactment of this Act. The amendment made by subsection (b) shall apply to gifts made after the date of the enactment of this Act. SEC. 103. FOREIGN TAX CREDIT FOR UNITED KINGDOM INCOME TAX PAID WITH RESPECT TO ROYALTIES, ETC. (a) CREDIT UNDER 1939 CODE.—Section 131(e) of the Internal Revenue Code of 1939 (relating to the foreign tax credit) is hereby 26 USC 905. amended by adding at the end thereof the following new sentence: "Foi" the purposes of this section, the recipient of a royalty or other amount paid or accrued as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret processes and formulas, trademarks, and other like property, and derived from sources within the United Kingdom of Great Britain and Northern Ireland, shall be deemed to have paid or accrued any income, warprofits, and excess-profits taxes paid or accrued to the United Kingdom with respect to such royalty or other amount (including the amount by which the payor's United Kingdom tax was increased by inability to deduct such royalty or other amount) if such recipient elects to include in its gross income the amount of such United Kingdom tax." (b) CREDIT UNDER 1954 CODE.—Section 905(b) of the Internal Revenue Code of 1954 is hereby amended by adding at the end thereof the following new sentence: "For purposes of this subpart, the recipient of a royalty or other amount paid or accrued as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret processes and formulas, trademarks, and other like property, and derived from sources within the United Kingdom of Great Britain and Northern Ireland, shall be deemed to have paid or accrued any income, war-profits and excess-profits taxes paid or accrued to the United Kingdom with respect to such royalty or other amount (including the amount by which the payor's United Kingdom tax was increased by inability to deduct such roj^alty or other amount) if such recipient elects to include in its gross income the amount of such United Kingdom tax." (c) EFFECTIVE DATE.—The amendment made by subsection (a) of this section shall apply for all taxable years beginning on or after January 1, 1950, as to which section 131 of the Internal Revenue Code of 1939 is the applicable provision. The amendment made by sub- 903 "|04°^90*5^' section (b) of this section shall apply with respect to taxable years ass! 7101.' beginning after December 31, 1953, and ending after August 16, 1954. No interest shall be allowed or paid on any overpayment resulting from the amendments made by subsections (a) and (b) of this section.

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