Irc Section 901

31 1978 see section 1 b of pub.

Irc section 901. 96 608 set out as an effective date of 1980 amendment note under section 913 of. Rules similar to the rules of section 913 j 4 of this title to apply for the purposes of applying this section for taxable years beginning in 1977 or 1978 in the case of an individual who leaves a foreign country after aug. Tax credit allowed under section 901 a and in the case of foreign income tax paid by a section 902 corporation as defined in section 909 d 5 will not be taken into account for purposes of section 902 or 960.

The amendment made by subparagraph a amending this section shall apply as if included in section 901 g of the internal revenue code of 1986 formerly i r c. The amendment made by subparagraph a amending this section shall apply as if included in section 901 g of the internal revenue code of 1986 formerly i r c. 1954 as added by section 1051 d 2 of the tax reform act of 1976 section 1051 d 2 of pub.

Citizens of the united states domestic corporations and certain aliens resident in the united states or puerto rico may choose to claim a credit as provided in section 901 against the tax imposed by chapter 1 of the internal revenue code code for taxes paid or accrued to foreign countries and possessions of the united states subject to the conditions prescribed in. 95 600 as amended by pub. 22 1986 100 stat.

Section 901 m 2 provides that a caa is. Section 701 u 1 c of pub. Instead the disqualified portion of any foreign income tax is allowed as a deduction.

2005 3 and irc 901 j. 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 sections 902 and 960. Paragraph 1 shall apply to those taxes paid.

For example a foreign levy identical to the tax imposed by section 11 of the internal revenue code is a single levy even though some provisions apply by their terms to some but not all corporations subject to the section 11 tax e g section 465 is by its terms applicable to corporations described in sections 465 a 1 b and 465 a 1 c. 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. Taxes paid to certain countries specified in irc 901 j are generally not creditable for years beginning after december 31 1986 see rev.