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.
Cited in 6 Tax Court opinions, 6 orders, and 5 briefs.
Current through Pub. L. 119-102 (2026-07-12).
← Back to Internal Revenue Code
This is a Docket.tax digital transcription provided for reference only and may lag the very latest amendments — always confirm against the official U.S. Code linked above. Docket.tax is an independent tool, not affiliated with, endorsed by, or operated by the Office of the Law Revision Counsel or the U.S. Tax Court.