Page:United States Statutes at Large Volume 96 Part 1.djvu/454

 96 STAT. 412 26 USC 667.

PUBLIC LAW 97-248—SEPT. 3, 1982 <'(C) any amount included in income under section 667, and "(2) increased by the amount of items of tax preference. "(c) CREDITS.—

26 USC 31.

"(1) IN GENERAL.—For purposes of determining any credit allowable under subpart A of part IV of this subchapter (other than the foreign tax credit allowed under section 33(a))— "(A) the tax imposed by this section shall not be treated as a tax imposed by this chapter, and "(B) the amount of the foreign tax credit allowed by section 33(a) shall be determined without regard to this section. "(2) FOREIGN TAX CREDIT ALLOWED AGAINST ALTERNATIVE MINI-

MUM TAX.— "(A) DETERMINATION OF FOREIGN TAX CREDIT.—The total amount of the foreign tax credit which can be taken against the tax imposed by subsection (a) shall be determined under subpart A of part III of subchapter N (section 901 and following). "(B) INCREASE IN AMOUNT OF FOREIGN TAXES TAKEN INTO

ACCOUNT.—For purposes of the determination provided by subparagraph (A), the amount of the taxes paid or accrued to foreign countries or possessions of the United States during the taxable year shall be increased by an amount equal to the lesser of— "(i) the foreign tax credit allowable under section 33(a) in computing the regular tax for the taxable year, or "(ii) the tax imposed by subsection (a). "(C) SECTION 904(a) LIMITATION.—For purposes of the determination provided by subparagraph (A), the limitation of section 904(a) shall be an amount equal to the same proportion of the sum of the tax imposed by subsection (a) against which such credit is taken and the regular tax as— "(i) the taxpayer's alternative minimum taxable income from sources without the United States (but not in excess of the taxpayer's entire alternative minimum taxable income), bears to "(ii) his entire alternative minimum taxable income. For such purpose, the amount of the limitation of section 904(a) shall not exceed the tax imposed by subsection (a). "(D) DEFINITION OF ALTERNATIVE MINIMUM TAXABLE INCOME FROM SOURCES WITHOUT THE UNITED STATES.—For

purposes of subparagraph (C), the term 'alternative minimum taxable income from sources without the United States' means adjusted gross income from sources without the United States, adjusted as provided in paragraphs (1) and (2) of subsection (b) (taking into account in such adjustment only items described in such paragraphs which are properly attributable to items of gross income from sources without the United States). "(E) SPECIAL RULE FOR APPLYING SECTION 904(C).—In

determining the amount of foreign taxes paid or accrued during the taxable year which may be deemed to be paid or accrued in a preceding or succeeding taxable year under section 904(c)--

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