56 CODIFICATION OF INTERNAL REVENUE LAWS SEC. 120. UNLIMITED DEDUCTION FOR CHARITABLE AND OTHER CONTRIBUTIONS. In the case of an individual if in the taxable year and in each of the ten preceding taxable years the amount of the contributions or gifts described in section 23 (o) (or corresponding provisions of prior revenue Acts) plus the amount of income, war-profits, or excess- profits taxes paid during such year in respect of preceding taxable years, exceeds 90 per centum of the taxpayer's net income for each such year, as computed without the benefit of the applicable subsec- tion, then the 15 per centum limit imposed by section 23 (o) shall not be applicable. SEC. 121. DEDUCTION OF DIVIDENDS PAID ON CERTAIN PREFERRED STOCK OF CERTAIN CORPORATIONS. In computing the net income of any national banking association, or of any bank or trust company organized under the laws of any State, Territory, possession of the United States, or the Canal Zone, or of any other banking corporation engaged in the business of industrial banking and under the supervision of a State banking department or of the Comptroller of the Currency, or of any incor- porated domestic insurance company, there shall be allowed as a deduction from gross income, in addition to deductions otherwise provided for in this chapter, any dividend (not including any distri- bution in liquidation) paid, within the taxable year, to the United States or to any instrumentality thereof exempt from Federal in- come taxes, on the preferred stock of the corporation owned by the United States or such instrumentality. The amount allowable as a deduction under this section shall be deducted from the basic surtax credit otherwise computed under section 27 (b). Supplement C-Credits Against Tax [Supplementary to Subchapter B, Part III] SEC. 131. TAXES OF FOREIGN COUNTRIES AND POSSESSIONS OF UNITED STATES. (a) ALLOWANCE OF CREDIT.- If the taxpayer signifies in his return his desire to have the benefits of this section, the tax imposed by this chapter shall be credited with: (1) CITIZEN AND DOMESTIC CORPORATION.- 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) RESIDENT OF UNITED STATES. -In the case of a resident of the United States, the amount of any such taxes paid or accrued during the taxable year to any possession of the United States; and (3) ALIEN RESIDENT OF UNITED STATES.- In the case of an alien resident of the United States, the amount of any such taxes paid or accrued during the taxable year to any foreign country, if the foreign country of which such alien resident is a citizen or subject, in imposing such taxes, allows a similar credit to citizens of the United States residing in such country; and (4) PARTNERSHIPS AND ESTATES.-In the case of any such indi- vidual who is a member of a partnership or a beneficiary of an estate or trust, his proportionate share of such taxes of the part- nership 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. (b) LIMIT ON CREDrr.- T he amount of the credit taken under this section shall be subject to each of the following limitations: (1) The amount of the credit in respect of the tax paid or accrued to any country shall not exceed the same proportion of the
�
