65 STAT.]
PUBLIC LAW 183—OCT. 20, 1951
subsection and section 301(b) of this Act had not been enacted and without inferences drawn from the fact that this subsection and the amendment made by section 301(b) are not expressly made applicable with respect to taxable years beginning before January 1, 1951."
503 ^u.^g c^j JQI
SEC 602. EXCESS PROFITS CREDIT BASED ON INCOME. (a) PERCENTAGE or AVERAGE BASE PERIOD N E T INCOME TAKEN INTO ACCOUNT.—
(1) IN GENERAL.—Paragraph (1)(A), and paragraph (2), of section 435(a) (relating to excess profits credit based on income) are each amended by striking out "85 per centum" and inserting in lieu thereof "83 per centum. (2) TAXABLE YEARS BEGINNING BEFORE JULY i, 1951, AND ENDING AFTER JUNE 30, 1951.—Section 435(a) is hereby amended by
26u!^s.c!f435(a).
Ante,p.m.
adding at the end thereof the following new paragraphs: "(4) CALENDAR YEAR 1951.—In the case of a taxable year beginning on January 1, 1951, and ending on December 31, 1951, there shall be used, for the purposes of paragraph (1)(A) and paragraph (2), in lieu of 85 per centum of the average base period net income, an amount equal to 84 per centum of the average base period net income. "(5)
T A X A B L E YEARS ( OTHER T H A N C A L E N D A R Y E A R 1951) B E G I N -
N I N G B E FOR E JULY 1, 1951, AND ENDING AFTER J U N E 30, 1951. — I n
the case of any taxable year (other than a taxable year described ih paragraph (4)) beginning before July 1, 1951, and ending after June 30, 1951, there shall be used, for the purposes of paragraph (1)(A) and paragraph (2), in lieu of 85 per centum of the average base period net income, an amount equal to the sum of— " (A) that portion of an amount equal to 85 per centum of the average base period net income which the number of days in such taxable year prior to July 1, 1951, bears to the total number of days in such taxable year, plus " (B) that portion of an amount equal to 83 per centum of the average base period net income which the number of days in such taxable year after June 30, 1951, bears to the total number of days m such taxable year." (b) EFFECTIVE DATE.—The amendments made by subsection (a) shall be applicable only with respect to taxable years ending after June 30, 1951. SEC. 603. FOREIGN ESTATE TAX CREDIT. (a) ClffiDiT AGAINST BASIC ESTATE TAX.—Section 813 (relating to credits against estate tax) is hereby amended by adding at the end thereof the following new subsection: "(c)
iu.^s. c^§8i3.
SAME—^PAID TO FOREIGN COUNTRIES.—
" (1) IN GENERAL.—The tax imposed by section 810 shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any foreign country in respect of any property situated within such foreign country and included in the gross estate (not including any such taxes paid with respect to the estate of a person other than the decedent). If the decedent at the time of his death was not a citizen of the United States, credit shall not be allowed under this subsection unless the foreign country of which such decedent was a citizen or subject, in imposing such taxes, allows a similar credit in the case of a citizen of the United States resident in such country. The determination of the country within which property is situated shall be made in accordance with the rules applicable under
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