applicable percentage

(ii)The term “applicable percentage” means the percentage determined in accordance with the following table: (iii) (I)An election under this subparagraph by any possession corporation may be made only for the corporation’s first taxable year beginning after, for which it is a possession corporation. (II)An election under this subparagraph shall apply to the taxable year for which made and all subsequent taxable years unless revoked. (III)If, for any taxable year, an election is not in effect for any possession corporation which is a member of an affiliated group, any election under this subparagraph for any other member of such group is revoked for such taxable year and all subsequent taxable years. For purposes of this subclause, members of an affiliated group shall be determined without regard to the exceptions contained in section 1504(b) and as if the constructive ownership rules of section 1563(e) applied for purposes of section 1504(a). The Secretary may prescribe regulations to prevent the avoidance of this subclause through deconsolidation or otherwise. (C)For definitions and special rules applicable to this paragraph, see subsection (i). (b)In determining taxable income for purposes of subsection (a), there shall not be taken into account as income from sources without the United States any gross income which was received by such domestic corporation within the United States, whether derived from sources within or without the United States. This subsection shall not apply to any amount described in subsection (a)(1)(A)(i) received from a person who is not a related person (within the meaning of subsection (h)(3) but without regard to subparagraphs (D)(ii) and (E)(i) thereof) with respect to the domestic corporation. (c)For purposes of this title, any tax of a foreign country or a possession of the United States which is paid or accrued with respect to taxable income which is taken into account in computing the credit under subsection (a) shall not be treated as income, war profits, or excess profits taxes paid or accrued to a foreign country or possession of the United States, and no deduction shall be allowed under this title with respect to any amounts so paid or accrued. (d)For purposes of this section—

Source

26 USC § 936(a)(4)(B)(ii)


Scoping language

None: Default is title Scope
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