Foreign Tax Credit

§ 27. Taxes of foreign countries and possessions of the United States The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901 11 So in original. Probably should be followed by a period. (Aug. 16, 1954, ch. 736, 68A Stat. 13, § 33; Pub. L. 94–455, title X, § 1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered § 27, Pub. L. 98–369, div. A, title IV, § 471(c), July 18, 1984, 98 Stat. 826; Pub. L. 115–141, div. U, title IV, § 401(d)(1)(A), Mar. 23, 2018, 132 Stat. 1206.) Editorial Notes Amendments2018—Pub. L. 115–141 amended section generally. Prior to amendment, section consisted of subsecs. (a) and (b) relating to the foreign tax credit under section 901 and the tax credit under section 936, respectively. 1984—Pub. L. 98–369, § 471(c), renumbered section 33 of this title as this section. 1976—Pub. L. 94–455 designated existing provisions as subsec. (a) and added subsec. (b). Statutory Notes and Related Subsidiaries Effective Date of 1976 AmendmentPub. L. 94–455, title X, § 1051(i), Oct. 4, 1976, 90 Stat. 1647, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “(1) Except as provided by paragraph (2), the amendments made by this section [enacting section 936 of this title and amending sections 33 [now 27], 48, 116, 243, 246, 861, 901, 904, 931, 1504, and 6091 of this title] shall apply to taxable years beginning after December 31, 1975, except that ‘qualified possession source investment income’ as defined in [former] section 936(d)(2) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] shall include income from any source outside the United States if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or his delegate that the income from such sources was earned before October 1, 1976. “(2) The amendment made by subsection (d)(2) [amending section 901 of this title] shall not apply to any tax imposed by a possession of the United States with respect to the complete liquidation occurring before January 1, 1979, of a corporation to the extent that such tax is attributable to earnings and profits accumulated by such corporation during periods ending before January 1, 1976.” Savings ProvisionFor provisions that nothing in amendment by Pub. L. 115–141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. 23, 2018, for purposes of determining liability for tax for periods ending after Mar. 23, 2018, see section 401(e) of Pub. L. 115–141, set out as a note under section 23 of this title.