26 U.S. Code § 78 - Dividends received from certain foreign corporations by domestic corporations choosing foreign tax credit

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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 section 902 (a) (relating to credit for corporate stockholder in foreign corporation) or under section 960 (a)(1) (relating to taxes paid by foreign corporation) for such taxable year shall be treated for purposes of this title (other than section 245) as a dividend received by such domestic corporation from the foreign corporation.


(Added Pub. L. 87–834, § 9(b),Oct. 16, 1962, 76 Stat. 1001; amended Pub. L. 94–455, title X, § 1033(b)(1),Oct. 4, 1976, 90 Stat. 1628.)

1976—Pub. L. 94–455substituted “section 902 (a)” for “section 902 (a)(1)” and “section 960 (a)(1)” for “section 960 (a)(1)(C)”.
Effective Date of 1976 Amendment

Amendment by Pub. L. 94–455applicable on different dates depending on the date the distributions were received, see section 1033(c) ofPub. L. 94–455, set out as a note under section 902 of this title.
Effective Date

Section applicable in respect of any distribution received by a domestic corporation after Dec. 31, 1964, and in respect of any distribution received by a domestic corporation before Jan. 1, 1965, in a taxable year of such corporation beginning after Dec. 31, 1962, but only to the extent that such distribution is made out of the accumulated profits of a foreign corporation for a taxable year (of such foreign corporation) beginning after Dec. 31, 1962, see section 9(e) ofPub. L. 87–834, set out as an Effective Date of 1962 Amendment note under section 902 of this title.

Written determinations for this section

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