[58 STAT. PUBLIC LAWS-CH. 63-FEB. 25, 1944 domestic corporation with respect to the accumulated profits of a foreign subsidiary) is amended to read as follows: "For the purposes of this section, a domestic corporation which owns a majority of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall be deemed to have paid the same proportion of any income, war-profits, or excess-profits taxes paid or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumu- lated profits of such foreign corporation from wich such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits." (c) TAxABRR YEAss TO WHICH APPLIcABiE. -The amendment made by subsection (a) shall be effective for all taxable years beginning ater December 31, 1941. The amendment made by subsection (b) shall be effective with respect to all taxable years beginning after December 31, 1939. SEC. 131. EXTENSION OF CONSOLIDATED RETURNS PRIVILEGE TO CERTAIN CORPORATIONS. 53 Stat. 59. 26 U. S. C., Supp. m, §14 (e). 54 Stat. 987, 988. 26U.S .C.S§725(a), 727 (e), (g), (h). Post, p. 58. 53 Stat. 61 . 26 U. S. C., Supp. III, 143 (b). 57 Stat. 128 . 26 U. 8. C., Supp. III, § 1622. Post, pp . 53,247, 253, 255. 56 Stat. 809. 26 U. S. O., Supp. III, § 162 (d). Section 141 (e) (relating to the definition of includible corpora- tions) is amended by adding at the end thereof the following new paragraph: "(7) Any corporation described in section 725 (a), or in section 727 (e), (g), or (h) (without regard to the exception in the initial clause of section 727) but not including such a corporation which has made and filed a consent, for the taxable year or any prior taxable year beginning after December 31, 1943 to be treated as an includible corporation. Such consent shall be made and filed at such time and in such manner as may be prescribed by the Commissioner with the approval of the Secretary." SEC. 132. NONRESIDENT ALIENS BROUGHT INTO UNITED STATES UNDER AUTHORITY OF WAR MANPOWER COMMISSION. (a) IN GENERAL. - Section 143 (b) (relating to withholding tax at source on nonresident alien individuals) is amended by inserting at the end thereof the following: "In respect of the compensation for services performed by nonresident alien individuals brought into the United States under the authority of the War Manpower Com- mission for temporary employment essential to the war effort and subject to withholding under this subsection, the deduction and with- holding shall be at the rate of 10 per centum, and there shall be no deduction or withholding under section 1622." (b) EEEOirw DATE.- The amendment made by subsection (a) shall be applicable to all compensation paid on or after the tenth day after the date of the enactment of this Act. SEC. 133. RELIEF IN THE CASE OF EXCESS DEDUCTIONS OF ESTATES AND TRUSTS. (a) IN GENErA. -Sect ion 162 (d), relating to deductions in com- puting the net income of estates and trusts, is amended by adding at the end thereof the following new paragraph: "(4) ExcEss DEDUCTIONS.- If for any taxable year of an estate or trust the deductions allowed under subsection (b) or (c) solely by reason of paragraph (2) or (3) (A) in respect of any income which becomes payable to a legatee, heir, or beneficiary exceed the net income of the estate or trust for such year, computed
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