Page:United States Statutes at Large Volume 76.djvu/1047

 76 STAT. ] (3)

PUBLIC LAW 8 7 - 8 3 4 - O C T. 16, 1962 ALTERNATIVE TAX ON CAPITAL GAINS.—Section 1201(a)

999 26 USC 1201.

(relating to alternative tax on corporations) is amended by striking out "821 (a)(1) or (b), " and inserting in lieu thereof "821 (a) o r (C),". (4) CLERICAL AMENDMENTS.—

^n'«' P-989.

(A) The table of parts for subchapter L is amended by striking out the portion referring to part II and inserting in lieu thereof the following: "Part II. Mutual insurance companies (other than life and certain marine insurance companies and other than fire or flood insurance companies which operate on basis of perpetual iwlicies or premium deposits)."

(B) The heading to section 831 is amended to read as follows:

"SEC. 831. TAX ON INSURANCE COMPANIES (OTHER THAN LIFE OR MUTUAL), MUTUAL MARINE INSURANCE COMPANIES, AND CERTAIN MUTUAL FIRE OR FLOOD INSURANCE COMPANIES." (C) The table of sections for part III of subchapter L is amended by striking out the portion referring to section 831 and inserting in lieu thereof the following: "Sec. 831. Tax on insurance companies (other than life or mutual), mutual marine insurance companies, and certain mutual fire or flood insurance companies."

(h) EFFECTIVE DATE.-—The amendments made by this section (other than h^ subsection (f)) shall apply with respect to taxable years beginning after December 31, 1962. SEC. 9. DOMESTICORPORATIONS RECEIVING DIVIDENDS FROM FOREIGN CORPORATIONS. (a) FOREIGN TAXES DEEMED PAID BY DOMESTIC (CORPORATIONS.—

Section 902 (relating to credit for corporate stockholder in foreign corporations) is amended to read as follows:

26 USC 902.

"SEC. 9 2 CREDIT FOR CORPORATE STOCKHOLDER IN FOREIGN 0. CORPORATION. " (a) TREATMENT OF TAXES PAID BY FOREIGN CORPORATION.—For

purposes of this subpart, a domestic corporation which owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall— "(1) to the extent such dividends are paid by such foreign corporation out of accumulated profits (as defined in subsection (c)(1)(A)) of a year for which such foreign corporation is not a less developed country corporation, be deemed to have paid the same proportion of any income, war profits^ or excess profits taxes paid'Or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends (determined without regard to section 78) bears Post, p. 1001. to the amount of such accumulated profits in excess of such income, war profits, and excess profits taxes (other than those deemed \- p a i d); and "(2) to the extent such dividends are paid by such foreign corporation out of accumulated profits (as defined in subsection (c)(1)(B)) of a year for which such foreign corporation is a less developed country corporation, be deemed to have paid the same proportion of any income, war profits, or excess profits taxes paid or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends bears to the amount of such accumulated profits.

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