---
kind: "section"
citation: "26 U.S.C. § 176"
title: "26"
title_heading: "Internal Revenue Code"
number: "176"
heading: "Payments with respect to employees of certain foreign corporations"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/176"
units:
  - "Subtitle A — Income Taxes"
  - "Chapter 1 — Normal Taxes and Surtaxes"
  - "Subchapter B — Computation of Taxable Income"
  - "Part VI — Itemized Deductions for Individuals and Corporations"
---

# §176. Payments with respect to employees of certain foreign corporations


In the case of a domestic corporation, there shall be allowed as a deduction amounts (to the extent not compensated for) paid or incurred pursuant to an agreement entered into under [section 3121(l)](/usc/26/3121.md?p=l) with respect to services performed by [United States](/usc/26/993.md?p=g) citizens employed by foreign [subsidiary corporations](/usc/26/424.md?p=f). Any reimbursement of any amount previously allowed as a deduction under this section shall be included in gross income for the taxable year in which received.


## Source credit

(Added Sept. 1, 1954, ch. 1206, title II, § 210(a), 68 Stat. 1096.)