PUBLIC LAW 94-455—OCT. 4, 1976
90 STAT. 1521
TABLE OF CONTENTS—Continued TITLE VII—ACCUMULATION TRUSTS Sec. 701. Accumulation trusts. TITLE VIII—CAPITAL FORMATION Sec. 801. Extension of $100,000 limitation on used property for 4 years. Sec. 802. Extension of 10 percent credit for 4' years and first-in-flrst-out treatment of investment credit amounts. Sec. 803. Employee stock ownership plans; study of expanded stock ownership. Sec. 804. Investment credit in the case of movie and television films. Sec. 805. Investment credit in the case of certain ships. Sec. 806. Additional net operating loss carryover year s; limitations on net operating loss carryovers. Sec. 807. Small fishing vessel construction reserves. TITLE IX—SMALL BUSINESS PROVISIONS Sec. 901. Extension of certain corporate income tax reductions. Sec. 902. Changes in subchapter S rules. TITLE X—CHANGES IN THE TREATMENT OF FOREIGN INCOME PART I—FOREIGN TAX PROVISIONS AFFECTING INDIVIDUALS ABROAD
Sec. 1011. Income earned abroad by United States citizens living or residing abroad. Sec. 1012. Income tax treatment of nonresident alien individuals who are married to citizens or residents of the United States. Sec. 1013. Foreign trusts having one or more United States beneficiaries to be taxed currently to grantor. Sec. 1014. Interest charge on accumulation distributions from foreign trusts. Sec. 1015. Excise tax on transfers of property to foreign persons to avoid Federal income tax. PART II—AMENDMENTS AFFECTING TAX TREATMENT OF CONTROLLED FOREIGN CORPORATIONS AND THE I R SHAREHOLDERS
Sec. 1021. Amendment of provision relating to investment in United States property by controlled foreign corporations. Sec. 1022. Repeal of exclusion for earnings of less developed country corporations for purposes of section 1248. Sec. 1023. Exclusion from subpart F of certain earnings of insurance companies. Sec. 1024. Shipping profits of foreign corporations. PART III—AMENDMENTS AFFECTING TREATMENT OF FOREIGN TAXES
Sec. 1031. Requirement that foreign tax credit be determined on overall basis. Sec. 1032. Recapture of foreign losses. Sec. 1033. Dividends from less developed country corporations to be grossed up for purposes of determining United States income and foreign tax credit against that income. Sec. 1034. Treatment of capital gains for purposes of foreign tax credit. Sec. 1035. Foreign oil and gas extraction income. Sec. 1036. Underwriting income. Sec. 1037. Third tier foreign tax credit when section 951 applies. PART IV—MONEY OR OTHER PROPERTY MOVING OUT OF OR INTO THE UNITED STATES
Sec. 1041. Portfolio debt investments in United States of nonresident aliens and foreign corporations. Sec. 1042. Changes in ruling requirements under section 367; certain changes in section 1248. Sec. 1043. Contiguous country branches of domestic life insurance companies. Sec. 1044. Transitional rule for bond, etc., losses of foreign banks. 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. Sec. 1052. Western Hemisphere trade corporations. Sec. 1053. Repeal of provisions relating to China Trade Act corporations.
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