US Codex
U.S.C.
Notes

§873. Deductions — Inbound Citations

26 U.S.C. § 873

Cited by 3 provisions in release 119-102.

Citations to §873(a)

  • 26 U.S.C. § 906(b)(1)
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    (1) For purposes of subsection (a) and for purposes of determining the deductions allowable under sections 873(a) and 882(c), in determining the amount of any tax paid or accrued to any foreign country or possession there shall not be taken into account any amount of tax to the extent the tax so paid or accrued is imposed with respect to income from sources within the United States which would not be taxed by such foreign country or possession but for the fact that—
    (A) in the case of a nonresident alien individual, such individual is a citizen or resident of such foreign country or possession, or
    (B) in the case of a foreign corporation, such corporation was created or organized under the law of such foreign country or possession or is domiciled for tax purposes in such country or possession.

Citations to §873(b)

  • 26 U.S.C. § 877(b)
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    (b) A nonresident alien individual described in subsection (a) shall be taxable for the taxable year as provided in section 1 or 55, except that—
    (1) the gross income shall include only the gross income described in section 872(a) (as modified by subsection (d) of this section), and
    (2) the deductions shall be allowed if and to the extent that they are connected with the gross income included under this section, except that the capital loss carryover provided by section 1212(b) shall not be allowed; and the proper allocation and apportionment of the deductions for this purpose shall be determined as provided under regulations prescribed by the Secretary.
    For purposes of paragraph (2), the deductions allowed by section 873(b) shall be allowed; and the deduction (for losses not connected with the trade or business if incurred in transactions entered into for profit) allowed by section 165(c)(2) shall be allowed, but only if the profit, if such transaction had resulted in a profit, would be included in gross income under this section. The tax imposed solely by reason of this section shall be reduced (but not below zero) by the amount of any income, war profits, and excess profits taxes (within the meaning of section 903) paid to any foreign country or possession of the United States on any income of the taxpayer on which tax is imposed solely by reason of this section.

Citations to §873(b)(3)