[§902. Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221 — repealed] — Inbound Citations

Citations to 26 U.S.C. § 902 as a whole

• 26 U.S.C. § 904(d)(2)(E)

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  (i) The term “noncontrolled 10-percent owned foreign corporation” means any foreign corporation which is—

  (I) a specified 10-percent owned foreign corporation (as defined in section 245A(b)), or

  (II) a passive foreign investment company (as defined in section 1297(a)) with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (or, for purposes of applying paragraphs (3) and (4), the requirements of section 902(b)).

  A controlled foreign corporation shall not be treated as a noncontrolled 10-percent owned foreign corporation with respect to any distribution out of its earnings and profits for periods during which it was a controlled foreign corporation. Any reference to section 902 in this clause shall be treated as a reference to such section as in effect before its repeal.

  (ii) If any foreign corporation is a noncontrolled 10-percent owned foreign corporation with respect to the taxpayer, any inclusion under section 1293 with respect to such corporation shall be treated as a dividend from such corporation.
• 26 U.S.C. § 904(d)(2)(E)(i)(II)

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  (II) a passive foreign investment company (as defined in section 1297(a)) with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (or, for purposes of applying paragraphs (3) and (4), the requirements of section 902(b)).
• 26 U.S.C. § 904(d)(2)(F)(ii)

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  (ii) the foreign income taxes deemed paid by the taxpayer with respect to such income under section 902¹ or 960,
• 26 U.S.C. § 1248(d)(3)

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  (3) Earnings and profits of a foreign corporation which were accumulated during any taxable year beginning before January 1, 1976, while such corporation was a less developed country corporation under section 902(d) as in effect before the enactment of the Tax Reduction Act of 1975.
• 26 U.S.C. § 1293(f)(3)

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  (3) a domestic corporation which owns (or is treated under section 1298(a) as owning) stock of a qualified electing fund shall be treated in the same manner as a United States shareholder of a controlled foreign corporation (and such qualified electing fund shall be treated in the same manner as such controlled foreign corporation) if such domestic corporation meets the stock ownership requirements of subsection (a) or (b) of section 902 (as in effect before its repeal) with respect to such qualified electing fund.
• 26 U.S.C. § 6038(a)(1)(B)

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  (B) in the case of a foreign corporation, its post-1986 undistributed earnings (as defined in section 902(c));¹