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U.S.C.
Notes

§904. Limitation on credit — Inbound Citations

26 U.S.C. § 904

Cited by 53 provisions in release 119-102.

Citations to 26 U.S.C. § 904 as a whole

  • 26 U.S.C. § 59(a)(1)(A)
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    (A) the pre-credit tentative minimum tax were the tax against which such credit was taken for purposes of section 904 for the taxable year and all prior taxable years beginning after December 31, 1986,
  • 26 U.S.C. § 59(a)(1)(B)
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    (B) section 904 were applied on the basis of alternative minimum taxable income instead of taxable income, and
  • 26 U.S.C. § 59(a)(3)(A)(ii)
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    (ii) the limitation of section 904 shall be based on the proportion which—
    (I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to
    (II) the taxpayer’s entire alternative minimum taxable income for the taxable year.
  • 26 U.S.C. § 245(a)(9)
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    (9) For purposes of section 904, the U.S.-source portion of any dividend received by a corporation from a qualified 10-percent owned foreign corporation shall be treated as from sources in the United States.
  • 26 U.S.C. § 841
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    The taxes imposed by foreign countries or possessions of the United States shall be allowed as a credit against the tax of a domestic insurance company subject to the tax imposed by section 801 or 831, to the extent provided in the case of a domestic corporation in section 901 (relating to foreign tax credit). For purposes of the preceding sentence (and for purposes of applying section 906 with respect to a foreign corporation subject to tax under this subchapter), the term “taxable income” as used in section 904 means—
  • 26 U.S.C. § 864(d)(2)(A)
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    (A) Section 904 (relating to limitation on foreign tax credit).
  • 26 U.S.C. § 901(a)
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    (a) If the taxpayer chooses to have the benefits of this subpart, the tax imposed by this chapter shall, subject to the limitation of section 904, be credited with the amounts provided in the applicable paragraph of subsection (b) plus, in the case of a corporation, the taxes deemed to have been paid under section 960. Such choice for any taxable year may be made or changed at any time before the expiration of the period prescribed for making a claim for credit or refund of the tax imposed by this chapter for such taxable year. The credit shall not be allowed against any tax treated as a tax not imposed by this chapter under section 26(b).
  • 26 U.S.C. § 901(b)
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    (b) Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a):
    (1) In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and
    (2) In the case of a resident of the United States and in the case of an individual who is a bona fide resident of Puerto Rico during the entire taxable year, the amount of any such taxes paid or accrued during the taxable year to any possession of the United States; and
    (3) In the case of an alien resident of the United States and in the case of an alien individual who is a bona fide resident of Puerto Rico during the entire taxable year, the amount of any such taxes paid or accrued during the taxable year to any foreign country; and
    (4) In the case of any nonresident alien individual not described in section 876 and in the case of any foreign corporation, the amount determined pursuant to section 906; and
    (5) In the case of any person described in paragraph (1), (2), (3), or (4), who is a member of a partnership or a beneficiary of an estate or trust, the amount of his proportionate share of the taxes (described in such paragraph) of the partnership or the estate or trust paid or accrued during the taxable year to a foreign country or to any possession of the United States, as the case may be. Under rules or regulations prescribed by the Secretary, in the case of any foreign trust of which the settlor or another person would be treated as owner of any portion of the trust under subpart E but for section 672(f), the allocable amount of any income, war profits, and excess profits taxes imposed by any foreign country or possession of the United States on the settlor or such other person in respect of trust income.
  • 26 U.S.C. § 906(b)(2)
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    (2) For purposes of subsection (a), in applying section 904 the taxpayer’s taxable income shall be treated as consisting only of the taxable income effectively connected with the taxpayer’s conduct of a trade or business within the United States.
  • 26 U.S.C. § 907(f)(2)(B)
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    (B) the amount by which the limitation provided by section 904 for such taxable year exceeds the sum of—
    (i) the taxes paid or accrued (or deemed to have been paid under section 960) to all foreign countries and possessions of the United States during such taxable year,
    (ii) the amount of such taxes which were deemed paid or accrued in such taxable year under section 904(c) and which are attributable to taxable years preceding the unused credit year, plus
    (iii) the amount of the foreign oil and gas taxes which by reason of this subsection are deemed paid or accrued in such taxable year and are attributable to taxable years preceding the unused credit year.
  • 26 U.S.C. § 960(c)(1)
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    (1) In the case of any taxpayer who—
    (A) either (i) chose to have the benefits of subpart A of this part for a taxable year beginning after September 30, 1993, in which he was required under section 951(a) to include any amount in his gross income, or (ii) did not pay or accrue for such taxable year any income, war profits, or excess profits taxes to any foreign country or to any possession of the United States,
    (B) chooses to have the benefits of subpart A of this part for any taxable year in which he receives 1 or more distributions or amounts which are excludable from gross income under section 959(a) and which are attributable to amounts included in his gross income for taxable years referred to in subparagraph (A), and
    (C) for the taxable year in which such distributions or amounts are received, pays, or is deemed to have paid, or accrues income, war profits, or excess profits taxes to a foreign country or to any possession of the United States with respect to such distributions or amounts,
    the limitation under section 904 for the taxable year in which such distributions or amounts are received shall be increased by the lesser of the amount of such taxes paid, or deemed paid, or accrued with respect to such distributions or amounts or the amount in the excess limitation account as of the beginning of such taxable year.
  • 26 U.S.C. § 960(c)(2)(C)
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    (C) For each taxable year beginning after September 30, 1993, for which the limitation under section 904 was increased under paragraph (1), the taxpayer shall reduce the amount in the excess limitation account by the amount of such increase.
  • 26 U.S.C. § 960(c)(3)
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    (3) If the taxpayer receives a distribution or amount in a taxable year beginning after September 30, 1993, which is excluded from gross income under section 959(a) and is attributable to any amount included in gross income under section 951(a) for a taxable year beginning before October 1, 1993, the limitation under section 904 for the taxable year in which such amount or distribution is received shall be increased by the amount determined under this subsection as in effect on the day before the date of the enactment of the Revenue Reconcilation2 Act of 1993.
  • 26 U.S.C. § 988(a)(3)(C)(i)
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    (i) For purposes of section 904 only, such loan shall be marked to market on an annual basis.

Citations to §904(a)

Citations to §904(b)

Citations to §904(b)(2)(B)

Citations to §904(b)(3)(D)

Citations to §904(b)(3)(E)

Citations to §904(c)

Citations to §904(d)

Citations to §904(d)(1)

Citations to §904(d)(2)

Citations to §904(d)(2)(A)

Citations to §904(d)(2)(B)(iii)(I)

Citations to §904(d)(2)(D)

Citations to §904(d)(2)(G)

Citations to §904(d)(2)(J)

Citations to §904(d)(3)

Citations to §904(d)(3)(C)

Citations to §904(d)(3)(D)

Citations to §904(f)

Citations to §904(f)(3)

Citations to §904(f)(5)

Citations to §904(h)

Citations to §904(h)(6)