1060 26 USC 901; fo3i' ^^ ^°°^'
26 USC 904. Ante, p. 999. Ante, p. 1020.
PUBLIC LAW 87-834-OCT. 16, 1962
[76 STAT.
" (A) ill applying section 901 (relating to taxes of foreign countries and possessions of the United States) to such United StateB person for the taxable year, the amount of taxes (other than taxes reduced under subparagraph (B)) paid or deemed paid (other than those deemed paid under section 904(d)) to any foreign country or possession of the United Statesi for the taxable year shall be reduced by 10 percent, and " (B) in ^bplying sectioiis 902 (relating to foreign tax credit for corporate stockholder in foreign corporation) and 960 (rclatii^ to special rules for foreign tax credit) to any such United States person which is a corporation (or to any person who acquires from any other person any portion of the i n t e r ^ t of such other person in any such foreign corporation J but only to the extent of such portion) for any taxable year, the amount of taxes paid or deemed paid by each foi/feign corporation with respect to which such person is required to furnish information during the annual accounting period or periods with respect to which such information is required under paragraph (2) of subsection (a) shall be reduced by 10 percent. If such failure continues 90 days or more after notice by the Secretary or his delegate to the United States person, then the amount of the reduction under this paragraph shall be 10 percent plus an additional 5 percent for each 3-month period, or fraction thereof, during which such failure to furnish information continues after the expiration of such 90-day period. "(2) LIMITATION.—The amount of the reduction under paragraph (1) for each failure to furnish information with respect to a foreign corporation required under subsection (a)(1) shall not exceed whichever of the following amounts is the greater: " (A) $10,000, or " (B) the income of the foreign corporation for its annual accounting period with respect to which the failure occurs. "(3)
SPECIAL RULES.—
" (A) No taxes shall be reduced under this subsection more than once for the same failure. " (B) For purposes of this subsection, the time prescribed under paragraph (2) of subsection (a) to furnish information (and the beginning of the 90-day period after notice by the Secretary) shall be treated as being not earlier than the last day on which (as shown to the satisfaction of the Secretary or his delegate) reasonable cause existed for failure to furnish such information. " (C) In applying subsections (a) and (b) of section 902, and in applying subsection (a) of section 960, the reduction provided by this subsection shall not apply for purposes of determining the amount of accumulated profits m excess of income, war profits, and excess profits taxes. "(c) Two O MORE PERSONS REQUIRED To F U R N I S H INFORMATION R W I T H RESPECT TO SAME FOREIGN CORPORATION.—Where, but for this
.subsection, two or more United States persons would be required to furnish information under subsection (a) with respect to the same foreign corporation for the same period, the Secretary or his delegate may by regulations provide that such information shall be required only from one person. To the extent practicable, the determination of which person shall furnish the information shall be made on the basis of actual ownership of stock.
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