Page:United States Statutes at Large Volume 74.djvu/1051

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[74 Stat. 1011]
[74 Stat. 1011]
PUBLIC LAW 86-000—MMMM. DD, 1960

74 S T A T. ]

PUBLIC LAW 8 6 - 7 8 0 - S E P T. 14, 1960

1011

"(2) ELECTION AFTER REVOCATION.—If a taxpayer has made an election under paragraph (1) and such election has been revoked, such taxpayer shall not be eligible to make a new election under paragraph (1) for any taxable year, unless the Secretary or his delegate consents to such new election. " (8) FORM AND TIME OF ELECTION AND REVOCATION.—An election

inider paragraph (1), and any revocation of such an election, may be made only in such manner as the Secretary or his delegate may by regulations prescribe. Such an election or revocation with respect to any taxable year may be made or changed at any time before the expiration of the period prescrib3d for making a claim for credit or refund of the tax imposed by this chapter for such taxable year." (b) Subsection (b) of such section 904 is amended— 68A Stat. 288. (1) by striking out " (b) " at the beginning and inserting ii:i lieu thereof " (c) "; and (2) by striking out "the limitation under subsection (a) " and inserting in lieu thereof "the applicable limitation under subsection (a) ". (c) Subsection (c) of such section 904 is amended— 72Stai. i639. (1) by striking out " (c) " at the beginning and inserting in lieu thereof " (d) "; and (2) by striking out "the limitation under subsection (a) " each place it appears m the first sentence and inserting in lieu thereof "the applicable limitation under subsection (a) ". (d) Such section 904 is amended by adding at the end thereof the ^^ Stat. i639. following new subsections: " (e) CARRYBACKS AND CARRYOVERS W H E R E OVERALL LIMITATION I S ELECTED.— " (1) FOREIGN TAXES TO BE AGGREGATED FOR PURPOSES or SUBSECTION (d).—With respect to each taxable year of the taxpayer to

which the limitation provided by subsection (a)(2) applies, the taxes referred to in the first sentence of subsection (d) shall, for purposes of applying such first sentence, be aggregated on an overall basis (rather than taken into account on a per-country basis). " (2) FOREIGN TAXES MAY NOT BE CARRIED FROM PER-COUNTRY YEAR TO OVERALL YEAR OR FROM OVERALL YEAR TO PER-COUNTRY

YEAR.—No amount -paid or accrued for any taxable year to which the limitation provided by subsection (a)(1) applies shall (except for purposes of determining the number oi taxable years which have elapsed) be deemed paid or accrued under subsection (d) in any taxable year to which the limitation provided by subsection (a)(2) applies. No amount paid or accrued for any taxable year to which the limitation provided by subsection (a)(2) applies shall (except for purposes of determining the number of taxable years which have elapsed) be deemed paid or accrued under subsection (d) in any taxable year to which the limitation provided by subsection (a)(1) applies. " (f) CROSS KEFERENCE.—

"For special rule relating to the application of the credit provided by section 901 in the case of affiliated groups which include Western Hemisphere trade corporations for years in which the limitation provided by subsection (a)(2) applies, see section 1503(d)."

SEC. 2. Section 1503 of the Internal Revenue Code of 1954 (relating to computation and payment of tax in case of consolidated returns) is amended by adding at the end thereof the following new subsection:

^^^ Stat. 367.