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26 U.S.C. § 908 — Reduction of credit for participation in or cooperation with an international boycott

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

26 U.S.C. § 908 — Reduction of credit for participation in or cooperation with an international boycott

**(a) In general** If a person, or a member of a controlled group (within the meaning of section 993(a)(3)) which includes such person, participates in or cooperates with an international boycott during the taxable year (within the meaning of section 999(b)), the amount of the credit allowable under section 901 to such person, or under section 960 to United States shareholders of such person, for foreign taxes paid during the taxable year shall be reduced by an amount equal to the product of— (1) the amount of the credit which, but for this section, would be allowed under section 901 for the taxable year, multiplied by (2) the international boycott factor (determined under section 999). **(b) Application with sections 275(a)(4) and 78** Section 275(a)(4) and section 78 shall not apply to any amount of taxes denied credit under subsection (a).

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Source location: Title 26, Chapter 1, § 908; chapter-001-normal-taxes-and-surtaxes.md

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

26 U.S.C. § 999 — Reports by taxpayers; determinations

**(a) International boycott reports by taxpayers** (1) **Report required** — If any person, or a member of a controlled group (within the meaning of section 993(a)(3)) which includes that person, has operations in, or related to— (A) a country (or with the government, a company, or a national of a country) which is on the list maintained by the Secretary under paragraph (3), or (B) any other country (or with the government, a company, or a national of that country) in which such person or such member had operations during the taxable year if such person (or, if such person is a foreign corporation, any United States shareholder of that corporation) knows or has reason to know that participation in or co-operation with an international boycott is required as a condition of doing business within such country or with such government, company, or national, that person or shareholder (within the meaning of section 951(b)) shall report such operations to the Secretary at such time and in such manner as the Secretary prescribes, except that in the case of a foreign corporation such report shall be required only of a United States shareholder (within the meaning of such section) of such corporation. (2) **Participation and cooperation; request therefor** — A taxpayer shall report whether he, a foreign corporation of which he is a United States shareholder, or any member of a controlled group which includes the taxpayer or such foreign corporation has participated in or cooperated with an international boycott at any time during the taxable year, or has been requested to participate in or cooperate with such a boycott, and, if so, the nature of any operation in connection with which there was participation in or cooperation with such boycott (or there was a request to

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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.

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

26 U.S.C. § 952 — Subpart F income defined

**(a) In general** For purposes of this subpart, the term “subpart F income” means, in the case of any controlled foreign corporation, the sum of— (1) insurance income (as defined under section 953), (2) the foreign base company income (as determined under section 954), (3) an amount equal to the product of— (A) the income of such corporation other than income which— (i) is attributable to earnings and profits of the foreign corporation included in the gross income of a United States person under section 951 (other than by reason of this paragraph), or (ii) is described in subsection (b), multiplied by (B) the international boycott factor (as determined under section 999), (4) the sum of the amounts of any illegal bribes, kickbacks, or other payments (within the meaning of section 162(c)) paid by or on behalf of the corporation during the taxable year of the corporation directly or indirectly to an official, employee, or agent in fact of a government, and (5) the income of such corporation derived from any foreign country during any period during which section 901(j) applies to such foreign country. The payments referred to in paragraph (4) are payments which would be unlawful under the Foreign Corrupt Practices Act of 1977 if the payor were a United States person. For purposes of paragraph (5), the income described therein shall be reduced, under regulations prescribed by the Secretary, so as to take into account deductions (including taxes) properly allocable to such income. **(b) Exclusion of United States income** In the case of a controlled foreign corporation, subpart F income does not include any item of income from sources within the United States which is effectively connected with the conduct by such corporation of a trade or business

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

26 U.S.C. § 995 — Taxation of DISC income to shareholders

**(a) General rule** A shareholder of a DISC or former DISC shall be subject to taxation on the earnings and profits of a DISC as provided in this chapter, but subject to the modifications of this subpart. **(b) Deemed distributions** (1) **Distributions in qualified years** — A shareholder of a DISC shall be treated as having received a distribution taxable as a dividend with respect to his stock in an amount which is equal to his pro rata share of the sum (or, if smaller, the earnings and profits for the taxable year) of— (A) the gross interest derived during the taxable year from producer’s loans, (B) the gain recognized by the DISC during the taxable year on the sale or exchange of property, other than property which in the hands of the DISC is a qualified export asset, previously transferred to it in a transaction in which gain was not recognized in whole or in part, but only to the extent that the transferor’s gain on the previous transfer was not recognized, (C) the gain (other than the gain described in subparagraph (B)) recognized by the DISC during the taxable year on the sale or exchange of property (other than property which in the hands of the DISC is stock in trade or other property described in section 1221(a)(1)) previously transferred to it in a transaction in which gain was not recognized in whole or in part, but only to the extent that the transferor’s gain on the previous transfer was not recognized and would have been treated as ordinary income if the property had been sold or exchanged rather than transferred to the DISC, (D) 50 percent of the taxable income of the DISC for the taxable year attributable to military property, (E) the taxable income of the DISC attributable to qualified export receipts of the DISC for the taxable yea

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

26 U.S.C. § 908 — Reduction of credit for participation in or

Page 2149 TITLE 26—INTERNAL REVENUE CODE § 908 into account (or not taken into account) in deter- mining foreign oil related income (as defined in old section 907(c)(2)). ‘‘(ii) An ‘old’ section is such section as in effect on the day before the date of the enactment of this Act [Sept. 3, 1982].’’ EFFECTIVE DATE OF 1978 AMENDMENT Amendment by section 301(b)(14) of Pub. L. 95–600 ap- plicable to taxable years beginning after Dec. 31, 1978, see section 301(c) of Pub. L. 95–600, set out as a note under section 11 of this title. Pub. L. 95–600, title VII, § 701(u)(8)(D), Nov. 6, 1978, 92 Stat. 2916, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: ‘‘(i) The amendments made by this paragraph [amending this section and section 904 of this title] shall apply, in the case of individuals, to taxable years ending after December 31, 1974, and, in the case of cor- porations, to taxable years ending after December 31, 1976. ‘‘(ii) In the case of any taxable year ending after De- cember 31, 1975, with respect to foreign oil related in- come (within the meaning of section 907(c) of the Inter- nal Revenue Code of 1986 [formerly I.R.C. 1954]), the overall limitation provided by section 904(a)(2) of such Code shall apply and the per-country limitation pro- vided by section 904(a)(1) of such Code shall not apply.’’ EFFECTIVE DATE OF 1976 AMENDMENT Amendment by section 1031(b)(6)(A) of Pub. L. 94–455 applicable to taxable years beginning after Dec. 31, 1975, with exceptions for certain mining operations, in- come from possessions, and carryback and carryover in the case of mining operations and income from a pos- session, see section 1031(c) of Pub. L. 94–455, set out as a note under section 904 of this title. Amendment by section 103

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