PUBLIC LAW 98-369—JULY 18, 1984
STAT. 995
"(1) IN GENERAL.—In the case of a domestic corporation, there shall be allowed as a deduction an amount equal to 100 percent .siMiS. of any dividend received by such corporation from another corporation which is distributed out of earnings and profits attributable to foreign trade income for a period during which such other corporation was a FSC. The deduction allowable under the preceding sentence with respect to any dividend shall be in lieu of any deduction allowable under subsection (a) or (b) with respect to such dividend. "(2) EXCEPTION FOR CERTAIN DIVIDENDS.—Paragraph (1) shall ^ not apply to any dividend which is distributed out of earnings •Mk r»ai r m and profits attributable to foreign trade income which— "(A) is section 923(a)(2) non-exempt income (within the Ante, p. 986. Ante, p. 991. ' ^ meaning of section 927(d)(6)), or "(B) would not, but for section 923(a)(4), be treated as exempt foreign trade income. "(3) DEFINITIONS.—For purposes of this subsection, the terms ,ia«: ••>fc0 m
- ' 'foreign trade income' and 'exempt foreign trade income' have
the meaning given such terms by section 923.". (2) CONFORMING AMENDMENTS.—
(A) Paragraph (1) of section 246(b) (relating to limitation 26 USC 246. on aggregate amount of deduction) is amended by striking out "245" each place it appears and inserting in lieu thereof "subsection (a) or (b) of section 245". (B) Subsection (d) of section 245 (relating to property Ante, p. 994. distributions), as redesignated by paragraph (1), is amended by striking out "subsections (a) and (b)" and inserting in lieu thereof "this section". (c) CLARIFICATION OF INFORMATION EXCHANGE AGREEMENTS.—Sub-
paragraph (D) of section 274(h)(6) (relating to coordination with section 6103) is amended— (1) by adding at the end thereof the following new sentence: "The Secretary may exercise his authority under subchapter A of chapter 78 to carry out any obligation of the United States under an agreement referred to in subparagraph (C).", and (2) by striking out the heading thereof and inserting in lieu
97 Stat. 395. 26 USC 274.
26 USC 7601 et seq.
thereof "COORDINATION WITH OTHER PROVISIONS.—". (d) CONFORMING AMENDMENTS.—
(1) Section 901 (relating to foreign tax credit) is amended by 26 USC 901. redesignating subsection (h) as subsection (i) and inserting after subsection (g) the following new subsection: "(h) TAXES PAID WITH RESPECT TO FOREIGN TRADE INCOME.—No
credit shall be allowed under this section for any income, war profits, and excess profits taxes paid or accrued with respect to the foreign trade income (within the meaning of section 923(b)) of a FSC, Ante, p. 986. other than section 923(a)(2) non-exempt income (within the meaning of section 927(d)(6).". Ante, p. 991. (2) Paragraph (1) of section 904(d) (relating to application of 26 USC 904. section in case of certain interest income and dividends from a DISC) as amended— (A) by striking out "and" at the end of subparagraph (B), •J9K (B) by striking out subparagraph (C) and inserting in lieu thereof the following: "(C) taxable income attributable to foreign trade income (within the meaning of section 923(b)),
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