564
26 %^^'i^c. «' ««?•
PUBLIC LAW 183—OCT. 20, 1951
§ 860
26u!^s.c°§8io.
iif Stat. 123; 62 Stat. 26 U.S.C. § 812.
[65 STAT.
Part III of this subchapter in determining whether property is situated within or without the United States. "(2) LIMITATIONS ON CREDIT.—The credit provided in this subsection with respect to such taxes paid to any foreign country— " (A) shall not, with respect to any such tax, exceed an amount which bears the same ratio to the amount of such tax actually paid to such foreign country as the value of property which is— "(i) situated within such foreign country, " ^ii) subjected to such tax, and "(iii) included in the gross estate bears to the value of all property subjected to such tax; and " (B) shall not, with respect to all such taxes, exceed an amount which bears the same ratio to the tax imposed by section 810 (after deducting from such tax the credits provided by subsections (a) and (b) of this section) as the value of property which is— "(i) situated within such foreign country, "(ii) subjected to the taxes of such foreign country, and "(iii) included in the gross estate bears to the value of the entire gross estate reduced by the aggregate amount of the deductions allowed under subsections (c), (d), and (e) of section 812. " (3) V A L U A T I O N OF PROPERTY.—
" (A) The values referred to in the ratio stated in paragraph (2)(A) are the values determined for the purposes of the tax imposed by such foreign country. " (B) The values referred to in the ratio stated in paragraph (2)(B) are the values determined under this chapter; but, in applying such ratio, the value of any property described in clauses (i), ( i i), and (iii) thereof shall be reduced by such amount as will properly reflect, in accordance with regulations prescribed by the Secretary, the deductions allowed in respect of such property under subsections (c), (d), and (e) of section 812. "(4) PROOF or CREDIT.—The credits provided in this subsection Post, p. 565.
^u.^s. c^§821.
i u^s W\871 i u^*s.^c'.1§-822. 871. '
aj^(j jj^ section 936(c) s h a l l be allowed only if the tax p a y e r estab-
lishes to the satisfaction of the Secretary (A) the amount of taxes actually paid to the foreign country, (B) the amount and date of each payment thereof, (C) the description and value of the property in respect of which such taxes are imposed, and (D) all other information necessary for the verification and computation of the credits. "(5) PERIOD OF LIMITATION.—The credits provided in this subsection and in section 936(c) shall be allowed only for such taxes as were actually paid and credit therefor claimed within four years after the filing of the return required by section 821, except that— " (A) If a petition for redetermination of a deficiency has been filed with The Tax Court of the United States within ^^® ^^"^® prescribed in section 871, then within such four-year period or before the expiration of 60 days after the decision of The Tax Court becomes final. " (B) If, under section 822(a)(2) or section 871(h), an extension of time has been granted for payment of the tax shown on the return, or of a deficiency, then within such fouryear period or before the date of the expiration of the period ' of the extension.
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