76 STAT.]
PUBLIC LAW 87-834-OCTa6, 1962
1027
" (f) REGULATIONS.—The Secretary or his delegate shall prescribe such regulations as he may deem necessary to carry out the provisions of this section, including regulations for the determination of the amount of foreign tax credit in the case of distributions with respect to the earnings and profits of two or more foreign corporations. "SEC. 964. MISCELLANEOUS PROVISIONS. " (a) EARNINGS AND PROFITS.—For purposes of this subpart, the earnings and profits of- any foreign corporation, and the deficit in earnings and profits of any foreign corporation, for any taxable year shall be determined according to rules substantially similar to those applicable to domestic corporations, under regulations prescribed by the Secretary or his delegate. "(b) BLOCKED FOREIGN INCOME.—Under regulations prescribed by the Secretary or his delegate, no part of the earnings and profits of a controlled foreign corporation for any taxable year shall be included in earnings and profits for purposes of sections 952, 955, and 956, if it is established to the satisfaction of the Secretary or his delegate that such part could not have been distributed by the controlled foreign corporation to United States shareholders who own (within the meaning of section 958(a)) stock of such controlled foreign corporation because of currency or other restrictions or limitations imposed under the laws of any foreign country. "(c)
RECORDS AND ACCOUNTS OF UNITED STATES SHAREHOLDERS.— "(1) RECORDS AND ACCOUNTS TO BE MAINTAINED.—The Secre-
tary or his delegate may by regulations require each person who is, or has been, a United States shareholder of a controlled foreign corporation to maintain such records and accounts as may be '^ prescribed by such regulations as necessary to carry out the provisions of this subpart and subpart G. "(2) Two OR MORE PERSONS REQUIRED TO MAINTAIN OR FURNISH THE SAME RECORDS AND ACCOUNTS WITH RESPECT TO THE SAME FOREIGN CORPORATION.—Where, but for this paragraph, two or more United States persons would be required to maintain or furnish the same records and accounts as may by regulations be required under paragraph (1) with respect to the same controlled foreign corporation for the same period, the Secretary or his delegate may by regulations provide that the maintenance or '>' furnishing of such records and accounts by only one such person shall satisfy the requirements of paragraph (1) for such other C persons.
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"Subpart G—Export Trade Corporations ,i
"Sec. 970. Reduction of subpart F income of export trade corporations. "Sec. 971. Definitions. " f^'• "Sec. 972. Consolidation of group of export trade corporations. "SEC. 970. REDUCTION O F SUBPART F INCOME OF E X P O R T TRADE CORPORATIONS. " (a) EXPORT TRADE I N C O M E C O N S T I T U T I N G FOREIGN B A S E C O M P A N Y INCOME,—
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" (1) IN GENERAL.—In the case of a controlled foreign corporation (as defined in section 957) which for the taxable year is an export trade corporation, the subpart F income (determined without regard to this subpart) of such corporation for such year shall be reduced by an amount equal to so much of the export trade income (as defined in section 971(b)) of such corporation for such year as constitutes foreign base company income (as defined
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Ante, p. 1017.
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