Browse Arkansas Code titles and sections

26 U.S.C. § 902 — Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221]

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 902 — Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221]

### Statutory Notes Section, act Aug. 16, 1954, ch. 736, 68A Stat. 286; Pub. L. 86–780, § 6(b)(2), Sept. 14, 1960, 74 Stat. 1016; Pub. L. 87–834, § 9(a), Oct. 16, 1962, 76 Stat. 999; Pub. L. 91–684, §§ 1, 2, Jan. 12, 1971, 84 Stat. 2068, 2069; Pub. L. 94–12, title VI, § 602(c)(6), Mar. 29, 1975, 89 Stat. 59; Pub. L. 94–455, title X, § 1033(a), Oct. 4, 1976, 90 Stat. 1626; Pub. L. 99–514, title XII, § 1202(a), Oct. 22, 1986, 100 Stat. 2528; Pub. L. 100–647, title I, § 1012(b)(1), (2), Nov. 10, 1988, 102 Stat. 3496; Pub. L. 105–34, title XI, §§ 1113(a), 1163(a), Aug. 5, 1997, 111 Stat. 970, 987; Pub. L. 108–357, title IV, § 405(a), Oct. 22, 2004, 118 Stat. 1498, related to deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation. #### Effective Date of Repeal Repeal applicable to taxable years of foreign corporations beginning after Dec. 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 14301(d) of Pub. L. 115–97, set out as an Effective Date of 2017 Amendment note under [section 78 of this title](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section78&num=0&edition=prelim).

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 902

Stored review status: release_metadata_unconfirmed. A text match is a research starting point; applicability is not established.

Original supplied file — preserved unchanged

Download original Markdown file

File SHA-256: 277876089fef8ce64009d813d8391fff9a2771e03edcaf69c84619d880b00f36. The original may include catalog metadata, neighboring provisions, or embedded records outside this collection's scope. Search shows only the selected federal record. Historical editions and unverified snapshots are not a statement of current law.

Authority boundary: historical or unconfirmed source not current law verified.

Open the recorded source website ↗

Record provenance

Stable record: federal_law:legal_authorities:record_usc_3ce1834f6d997ded3a65d519
Source file: Laws/federal/codes/united-states-code/title-26/section-902-repealed-pub-l-11597-title-i-14301-a-dec-22-2017-131-stat-2221--8e0ab3813a.md
Pages: Not recorded – Not recorded
Passage SHA-256: e8e5626b815de6ea807bcb6a205dfcf3a8c6285ee251101881f38934bde8372b

Source location: Title 26, Chapter 1, § 902; chapter-001-normal-taxes-and-surtaxes.md

Stored source content

Cross-references

Connections may be documented source relationships, shared citations or nearby passages. Each explains its basis; a connection alone does not establish applicability to your situation.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 78 — Gross up for deemed paid foreign tax credit

If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under subsections (a) and (d) of section 960 (determined without regard to the phrase “90 percent of” in subsection (d)(1) thereof) for such taxable year shall be treated for purposes of this title (other than sections 245 and 245A) as a dividend received by such domestic corporation from the foreign corporation.

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 78

Stored review status: release_metadata_unconfirmed. Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 1293 — Current taxation of income from qualified electing funds

**(a) Inclusion** (1) **In general** — Every United States person who owns (or is treated under section 1298(a) as owning) stock of a qualified electing fund at any time during the taxable year of such fund shall include in gross income— (A) as ordinary income, such shareholder’s pro rata share of the ordinary earnings of such fund for such year, and (B) as long-term capital gain, such shareholder’s pro rata share of the net capital gain of such fund for such year. (2) **Year of inclusion** — The inclusion under paragraph (1) shall be for the taxable year of the shareholder in which or with which the taxable year of the fund ends. **(b) Pro rata share** The pro rata share referred to in subsection (a) in the case of any shareholder is the amount which would have been distributed with respect to the shareholder’s stock if, on each day during the taxable year of the fund, the fund had distributed to each shareholder a pro rata share of that day’s ratable share of the fund’s ordinary earnings and net capital gain for such year. To the extent provided in regulations, if the fund establishes to the satisfaction of the Secretary that it uses a shorter period than the taxable year to determine shareholders’ interests in the earnings of such fund, pro rata shares may be determined by using such shorter period. **(c) Previously taxed amounts distributed tax free** If the taxpayer establishes to the satisfaction of the Secretary that any amount distributed by a passive foreign investment company is paid out of earnings and profits of the company which were included under subsection (a) in the income of any United States person, such amount shall be treated, for purposes of this chapter, as a distribution which is not a dividend; except that such distribution shall immed

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 1293

Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6038 — Information reporting with respect to certain foreign corporations and partnerships

**(a) Requirement** (1) **In general** — Every United States person shall furnish, with respect to any foreign business entity which such person controls, such information as the Secretary may prescribe relating to— (A) the name, the principal place of business, and the nature of business of such entity, and the country under whose laws such entity is incorporated (or organized in the case of a partnership); (B) in the case of a foreign corporation, its post-1986 undistributed earnings (as defined in section 902(c)); 11 See References in Text note below. (C) a balance sheet for such entity listing assets, liabilities, and capital; (D) transactions between such entity and— (i) such person, (ii) any corporation or partnership which such person controls, and (iii) any United States person owning, at the time the transaction takes place— (I) in the case of a foreign corporation, 10 percent or more of the value of any class of stock outstanding of such corporation, and (II) in the case of a foreign partnership, at least a 10-percent interest in such partnership; and (E) (i) in the case of a foreign corporation, a description of the various classes of stock outstanding, and a list showing the name and address of, and number of shares held by, each United States person who is a shareholder of record owning at any time during the annual accounting period 5 percent or more in value of any class of stock outstanding of such foreign corporation, and (ii) information comparable to the information described in clause (i) in the case of a foreign partnership. The Secretary may also require the furnishing of any other information which is similar or related in nature to that specified in the preceding sentence or which the Secre

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6038

Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 901 — Taxes of foreign countries and of possessions of United States

**(a) Allowance of credit** If the taxpayer chooses to have the benefits of this subpart, the tax imposed by this chapter shall, subject to the limitation of section 904, be credited with the amounts provided in the applicable paragraph of subsection (b) plus, in the case of a corporation, the taxes deemed to have been paid under section 960. Such choice for any taxable year may be made or changed at any time before the expiration of the period prescribed for making a claim for credit or refund of the tax imposed by this chapter for such taxable year. The credit shall not be allowed against any tax treated as a tax not imposed by this chapter under section 26(b). **(b) Amount allowed** Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) **Citizens and domestic corporations** — In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) **Resident of the United States or Puerto Rico** — In the case of a resident of the United States and in the case of an individual who is a bona fide resident of Puerto Rico during the entire taxable year, the amount of any such taxes paid or accrued during the taxable year to any possession of the United States; and (3) **Alien resident of the United States or Puerto Rico** — In the case of an alien resident of the United States and in the case of an alien individual who is a bona fide resident of Puerto Rico during the entire taxable year, the amount of any such taxes paid or accrued during the taxable year to any foreign country; and (4) **Nonresident alien individuals an

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 901

Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 904 — Limitation on credit

**(a) Limitation** The total amount of the credit taken under section 901(a) shall not exceed the same proportion of the tax against which such credit is taken which the taxpayer’s taxable income from sources without the United States (but not in excess of the taxpayer’s entire taxable income) bears to his entire taxable income for the same taxable year. **(b) Taxable income for purpose of computing limitation** (1) **Personal exemptions** — For purposes of subsection (a), the taxable income in the case of an individual, estate, or trust shall be computed without any deduction for personal exemptions under section 151 or 642(b). (2) **Capital gains** — For purposes of this section— (A) *In general* — Taxable income from sources outside the United States shall include gain from the sale or exchange of capital assets only to the extent of foreign source capital gain net income. (B) *Special rules where capital gain rate differential* — In the case of any taxable year for which there is a capital gain rate differential— (i) in lieu of applying subparagraph (A), the taxable income from sources outside the United States shall include gain from the sale or exchange of capital assets only in an amount equal to foreign source capital gain net income reduced by the rate differential portion of foreign source net capital gain, (ii) the entire taxable income shall include gain from the sale or exchange of capital assets only in an amount equal to capital gain net income reduced by the rate differential portion of net capital gain, and (iii) for purposes of determining taxable income from sources outside the United States, any net capital loss (and any amount which is a short-term capital loss under section 1212(a)) from sources outside the United States to

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 904

Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 960 — Deemed paid credit for subpart F inclusions

**(a) In general** For purposes of subpart A of this part, if there is included in the gross income of a domestic corporation any item of income under section 951(a)(1) with respect to any controlled foreign corporation with respect to which such domestic corporation is a United States shareholder, such domestic corporation shall be deemed to have paid so much of such foreign corporation’s foreign income taxes as are properly attributable to such item of income. **(b) Special rules for distributions from previously taxed earnings and profits** For purposes of subpart A of this part— (1) **In general** — If any portion of a distribution from a controlled foreign corporation to a domestic corporation which is a United States shareholder with respect to such controlled foreign corporation is excluded from gross income under section 959(a), such domestic corporation shall be deemed to have paid so much of such foreign corporation’s foreign income taxes as— (A) are properly attributable to such portion, and (B) have not been deemed to have to 11 So in original. been paid by such domestic corporation under this section for the taxable year or any prior taxable year. (2) **Tiered controlled foreign corporations** — If section 959(b) applies to any portion of a distribution from a controlled foreign corporation to another controlled foreign corporation, such controlled foreign corporation shall be deemed to have paid so much of such other controlled foreign corporation’s foreign income taxes as— (A) are properly attributable to such portion, and (B) have not been deemed to have been paid by a domestic corporation under this section for the taxable year or any prior taxable year. **(c) Special rules for foreign tax credit in year of receipt of previously taxed ea

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 960

Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 902 — Untitled legal text

Page 2118 TITLE 26—INTERNAL REVENUE CODE [§ 902 able year under section 402(e) (relating to tax on lump sum distributions), applicable only with respect to dis- tributions or payments made after Dec. 31, 1973, in tax- able years beginning after Dec. 31, 1973, see section 2005(d) of Pub. L. 93–406, set out as a note under section 402 of this title. EFFECTIVE DATE OF 1971 AMENDMENT Amendment by Pub. L. 92–178 applicable with respect to taxable years ending after Dec. 31, 1971, except that a corporation may not be a DISC for any taxable year beginning before Jan. 1, 1972, see section 507 of Pub. L. 92–178, set out as an Effective Date note under section 991 of this title. EFFECTIVE DATE OF 1969 AMENDMENT Amendment by section 301(b)(9) of Pub. L. 91–172 ap- plicable to taxable years ending after Dec. 31, 1969, see section 301(c) of Pub. L. 91–172, set out as a note under section 5 of this title. Pub. L. 91–172, title V, § 506(c), Dec. 30, 1969, 83 Stat. 635, provided that: ‘‘The amendments made by this sec- tion [amending this section and section 904 of this title] shall apply with respect to taxable years beginning after December 31, 1969.’’ EFFECTIVE DATE OF 1966 AMENDMENT Amendment by section 106(a)(4), (5) of Pub. L. 89–809 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 106(a)(6) of Pub. L. 89–809, set out as a note under section 874 of this title. Pub. L. 89–809, title I, § 106(b)(4), Nov. 13, 1966, 80 Stat. 1570, provided that: ‘‘The amendments made by this subsection (other than paragraph (3)) [amending this section] shall apply with respect to taxable years be- ginning after December 31, 1966. The amendment made by paragraph (3) [amending section 2014 of this title] shall apply with respect to estates

Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 902

Stored review status: historical_2024_not_currentness_verified. Same stored citation; legal effect and authority still require review.