§907. Special rules in case of foreign oil and gas income — Inbound Citations
26 U.S.C. § 907
Cited by 8 provisions in release 119-102.
Citations to 26 U.S.C. § 907 as a whole
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(10) If—(A) any portion of a dividend received by a corporation from a qualified 10-percent-owned foreign corporation would be treated as from sources in the United States under paragraph (9),(B) under a treaty obligation of the United States (applied without regard to this subsection), such portion would be treated as arising from sources outside the United States, and(C) the taxpayer chooses the benefits of this paragraph,
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(A) If—(i) without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States,(ii) under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and(iii) the taxpayer chooses the benefits of such treaty obligation,
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(A) If—(i) any amount derived from a United States-owned foreign corporation would be treated as derived from sources within the United States under this subsection by reason of an item of income of such United States-owned foreign corporation,(ii) under a treaty obligation of the United States (applied without regard to this subsection and by treating any amount included in gross income under section 951(a)(1) as a dividend), such amount would be treated as arising from sources outside the United States, and(iii) the taxpayer chooses the benefits of this paragraph,
Citations to §907(c)(1)
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(B) For purposes of subparagraph (A), the term “domestic oil and gas extraction income” means income described in section 907(c)(1), determined by substituting “within the United States” for “without the United States”.
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(V) any foreign oil and gas extraction income (as defined in section 907(c)(1)) of such corporation, over
Citations to §907(c)(4)(B)
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(iii) The term “separate limitation loss” means, with respect to any income category, the loss from such category determined under the principles of section 907(c)(4)(B).
Citations to §907(f)
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(i) In the case of a deficiency attributable to the application to the taxpayer of a carryback under section 904(c) (relating to carryback and carryover of excess foreign taxes) or under section 907(f) (relating to carryback and carryover of disallowed foreign oil and gas taxes), such deficiency may be assessed at any time before the expiration of one year after the expiration of the period within which a deficiency may be assessed for the taxable year of the excess taxes described in section 904(c) or 907(f) which result in such carryback.