Taxes of foreign countries and possessions of the United States
11 So in original. Probably should be followed by a period.The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901
Pub. L. 115–1412018— amended section generally. Prior to amendment, section consisted of subsecs. (a) and (b) relating to the foreign tax credit under section 901 and the tax credit under section 936, respectively.
section 936 of this title Except as provided by paragraph (2), the amendments made by this section [enacting and amending sections 33 [now 27], 48, 116, 243, 246, 861, 901, 904, 931, 1504, and 6091 of this title] shall apply to taxable years beginning after , except that ‘qualified possession source investment income’ as defined in [former] section 936(d)(2) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] shall include income from any source outside the United States if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or his delegate that the income from such sources was earned before .
“(2)
section 901 of this title The amendment made by subsection (d)(2) [amending ] shall not apply to any tax imposed by a possession of the United States with respect to the complete liquidation occurring before , of a corporation to the extent that such tax is attributable to earnings and profits accumulated by such corporation during periods ending before .”
, , , as amended by , , , provided that:
Savings Provision
Pub. L. 115–141section 401(e) of Pub. L. 115–141section 23 of this titleFor provisions that nothing in amendment by be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to , for purposes of determining liability for tax for periods ending after , see , set out as a note under .