PUBLIC LAW 94-455—OCT. 4, 1976
90 STAT. 1643
for such taxable year (but not in excess of the net capital loss for such taxable year). ' ' (b) EFFKcrrvE D A T E. —
(1) The amendment made by subsection (a) shall apply with respect to taxable years beginning after July 11, 1900. (2) If the refund or credit of any overpayment attributablo to the application of the amendment made by subsection (a) to any taxable year is otherAvise prevented by the operation of any law or rule of law (other than section 7122 of the I n t e r n a l Revenue Code of 1954, relating to compromises) on the day which is one year after- the date of the enactment of this Act. such credit or refund shall be nevertheless allowed or made if claim therefor is filed on or before such day.
26 USC 582
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PART V—SPECIAL CATEGORIES OF FOREIGN TAX TREATMENT SEC. 1051. TAX TREATMENT OF CORPORATIONS CONDUCTING TRADE OR BUSINESS IN PUERTO RICO AND POSSESSIONS OF THE UNITED STATES. (a) ALLOAVAXCE OV PrKnro R I C A X AXD Possicssiox T A X CKKuri.— Section 33 (relating to taxes of foreign countries and possessions of ^6 USC 33. the United States) is amended to read as follows: "SEC. 33. TAXES OF FOREIGN COUNTRIES AND POSSESSIONS OF THE UNITED STATES; POSSESSION TAX CREDIT. " (a) FoREUJX TAX Cin.niT.—The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a ci'edit against the tax imposed by this chapter to the extent provided in section 901. " (b) SECTIOX 936 CiiEmT.—In the case of a domestic corporation. the amount provided by section 936 (relating to l*uerto Rico and pos- Infra. session tax credit) shall be allowed as a credit against the tax imposed by this chapter." (b) IvUEES ox PossESsu)X' T A X CREDIT.—Subpart I) of part III of subchapter I T of chapter 1 (relating to possessions of the United S \ • States) is amended b_y adding at the end thereof the following new section: "SEC. 936. PUERTO RICO AND POSSESSION TAX CREDIT. "(a)
ALLOWAXCE or
26 USC 936.
CREDIT.—
' ' (1) I x GEXEKAL.—Except as provided in paragraph (2), in the case of a domestic corporation which elects the application of this section, there shall be allowed as a credit against the tax imposed by this chapter an amount equal to the j^ortion of the tax which is attributable to taxable income, from sources without the United States, from the active conduct of a trade or business within a possession of the United States, and from qualified possession source investment income, if the conditions of both subparagraph (A) and subparagraph (B) are satisfied: " (A) 3-YEAU PERTOD.—If 80 pcrccjit Or more of the gross income of such domestic corporation for the 3-3'ear period immediately preceding the close of the taxable year (or for such p a i t of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States (determined without regard to sectioji 904 (f)); and
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