§78. Gross up for deemed paid foreign tax credit — Inbound Citations

Citations to 26 U.S.C. § 78 as a whole

• 26 U.S.C. § 163(j)(8)(A)(vi)

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  (vi) the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and
• 26 U.S.C. § 250(a)(1)(B)(ii)

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  (ii) the amount treated as a dividend received by such corporation under section 78 which is attributable to the amount described in clause (i).
• 26 U.S.C. § 901(j)(3)

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  (3) Sections 275 and 78 shall not apply to any tax which is not allowable as a credit under subsection (a) by reason of this subsection.
• 26 U.S.C. § 901(k)(7)

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  (7) Sections 275 and 78 shall not apply to any tax which is not allowable as a credit under subsection (a) by reason of this subsection.
• 26 U.S.C. § 901(m)(6)

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  (6) Sections 275 and 78 shall not apply to any tax which is not allowable as a credit under subsection (a) by reason of this subsection.
• 26 U.S.C. § 904(d)(2)(F)

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  (F) The term “high-taxed income” means any income which (but for this subparagraph) would be passive income if the sum of—

  (i) the foreign income taxes paid or accrued by the taxpayer with respect to such income, and

  (ii) the foreign income taxes deemed paid by the taxpayer with respect to such income under section 902¹ or 960,

  exceeds the highest rate of tax specified in section 1 or 11 (whichever applies) multiplied by the amount of such income (determined with regard to section 78). For purposes of the preceding sentence, the term “foreign income taxes” means any income, war profits, or excess profits tax imposed by any foreign country or possession of the United States.
• 26 U.S.C. § 904(d)(3)(G)

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  (G) For purposes of this paragraph, the term “dividend” includes any amount included in gross income in section 951(a)(1)(B). Any amount included in gross income under section 78 to the extent attributable to amounts included in gross income in section 951(a)(1)(A) shall not be treated as a dividend but shall be treated as included in gross income under section 951(a)(1)(A).
• 26 U.S.C. § 908(b)

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  (b) Section 275(a)(4) and section 78 shall not apply to any amount of taxes denied credit under subsection (a).
• 26 U.S.C. § 965(g)(4)

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  (4) With respect to the taxes treated as paid or accrued by a domestic corporation with respect to amounts which are includible in gross income of such domestic corporation by reason of this section, section 78 shall apply only to so much of such taxes as bears the same proportion to the amount of such taxes as—

  (A) the excess of—

  (i) the amounts which are includible in gross income of such domestic corporation by reason of this section, over

  (ii) the deduction allowable under subsection (c) with respect to such amounts, bears to

  (B) such amounts.
• 26 U.S.C. § 1291(g)(1)(A)

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  (A) the amount of such distribution shall be determined for purposes of this section with regard to section 78,