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INTERNAL REVENUE CODE OF 19 54 (3) A L I E N RESIDENT OF THE UNITED STATES OR PUERTO RICO.—In
the case of an alien resident of the United States and in the case of an ahen individual who is a bona fide resident of Puerto Rico during the entire taxable year, 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 individual described in paragraph (1), (2), or (3), who is a member of a partnership or a beneficiary of an estate or trust, the amount of his proportionate share of the taxes (described in such paragraph) of the partnership 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. (c) CORPORATIONS TREATED AS FOREIGN. — For purposes of this subpart, the following corporations shall be treated as foreign corporations: (1) a corporation entitled to the benefits of section 931, by reason of receiving a large percentage of its gross income from sources within a possession of the United States; and (2) a corporation organized under the China Trade Act, 1922 (15 U.S.C. chapter 4), and entitled to the deduction provided in section 941. (d) CROSS E E E E R E N C E. — (1) For deductions of income, war profits, and excess profits taxes paid to a foreign country or a possession of the United States, see section 164. (2) For right of each partner to malie election under this section, see section 703(b). (3) For right of estate or trust to the credit for taxes imposed by foreign countries and possessions of the United States under this section, see section 642(a)(2).
SEC. 902. CREDIT FOR CORPORATE STOCKHOLDER IN FOREIGN CORPORATION. (a) TREATMENT OF T A X E S PAID BY FOREIGN CORPORATION.—For
purposes of this subpart, a domestic corporation which owns at least 10 percent 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, on or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits. (b) FOREIGN SUBSIDIARY OF FOREIGN CORPORATION.—If such foreign corporation owns 50 percent or more of the voting stock of another foreign corporation from which it receives dividends in any taxable year, it shall be deemed to have paid the same proportion of any income, war profits, or excess profits taxes paid by such other foreign corporation to any foreign country or to any possession of the United States, on or with respect to the accumulated profits of the corporation from which such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits. § 901(b)(3)
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