Page:United States Statutes at Large Volume 76.djvu/1079

 76 STAT.]

PUBLIC LAW 8 7 - 8 3 4 - O C T. 16, 1962

No expense incurred within the United States shall be treated as an export promotion expense within the meaning of the preceding sentence, unless at least 90 percent of each category of expenses described in such sentence is incurred outside the United States. "(e) EXPORT PROPERTY.—For purposes of this subpart, the term 'export property' means any property or any interest in property manufactured, produced, grown, or extracted in the United States. " (f) UNRELATED PERSON.—For purposes of this subpart, the term 'unrelated person' means a person other than a related person as defined in section 954(d)(3).

Wlf

Ante, p. 1012.

"SEC. 9 2 CONSOLIDATION OF GROUP OF EXPORT TRADE CORPORA7. TIONS. "For purposes of this subpart and subpart F of this part, a United States shareholder of a controlled foreign corporation which is an export trade corporation may, under regulations prescribed by the Secretary or his delegate, treat as a single controlled foreign corporation— "(1) such controlled foreign corporation, 5 "(2) all controlled foreign corporations which are export trade r corporations and 80 percent or more of the total combined voting power of all classes of stock entitled to vote of which is owned by such controlled foreign corporation; and "(3) all controlled foreign corporations which are export trade corporations and 80 percent or more of the total combined voting power of all classes of stock entitled to vote of which is owned by controlled foreign corporations described in paragraph (2)." / (b)

TECHNICAL AND CLERICAL AMENDMENTS.—

(1) Section 901 (relating to foreign tax credit) is amended by striking out "section 902" and inserting in lieu thereof "sections 902 and 960". (2) Section 904(g) (as redesignated by section 10(a) of this Act) is amended to read as follows: "(g)

Ante. p. 1002.

CROSS REFERENCES.—

"(1) For increase of applicable limitation under subsection (a) for taxes paid with respect to amounts received which were included in the gross income of the taxpayer for a prior taxable year as a United States shareholder with respect to a controlled foreign ' corporation, see section 960(b). "(2) For special rule relating to the application of the credit t provided by section 901 in the case of aflSliated groups which include Western Hemisphere trade corporations for years in which the limitation provided by subsection (a)(2) applies, see section 1503(d).'' (3) The table of subparts for part H I of subchapter N of chapter 1 is amended by adding at the end thereof the following: > "Subpart F. Controlled foreign corporations. "Subpart G. Export trade corporations." (4) Section 1016(a) (relating to adjustments to basis) is amended by adding after paragraph (19) (as added by section 2(f) of this Act) the following new paragraph: "(20) to the extent provided in section 961 in the case of stock i in controlled foreign corporations (or foreign corporations which were controlled foreign corporations) and of property by reason " of which a person is considered as owning such stock." (c) EFFECTIVE DATE.—The amendments made by this section shall apply with respect to taxable years of foreign corporations beginning after December 31, 1962, and to taxable years of United States shareholders within which or with which such taxable years of such foreign corporations end.

Ante, p. 1020. 74 Stat. lO 11. 26 USC 90 i-90S. Ante, p. 972.

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