PUBLIC LAW 94-455—OCT. 4, 1976 "(5)
90 STAT. 1633
O I L AND GAS EXTRACTION TAXES.—The term 'oil and gas
extraction taxes' means any income, w a r profits, and excess profits tax p a i d or accrued (or deemed to have been p a i d under section 902 or 960) during the taxable year with respect to foreign oil Ante, p. 1626. and gas extraction income (determined without regard to para- 26 USC 960. g r a p h (4)) or loss which would be taken into account for purposes of section 901 without regard to this section." (3) TECHXICAL AMENDMENT.—Subsection (i) of section 6501, as
amended by section 1031, (relating to foreign tax carrybacks) is 26 USC 6501. amended— (A) by striking out "excess foreign tax e s) " and inserting in lieu thereof "excess foreign taxes) or under section 907(f) ^'*^^» P- 1631. (relating to carryback and carryover of disallowed oil and gas extraction tax e s) "; and (B) by striking out "section 9 0 4 (c) " the second place it appears and inserting in lieu thereof "section 904(c) or 907(f)". (e)
EFTECTIVE D A T E S. —
26 USC 907
(1) The amendment made by subsection (a) shall apply to tax- note, able years ending after December 31, 1976. (2) The amendment made by subsection (b) shall apply to taxable years ending after December 31, 1974; except that the last sentence of section 907(b) of the I n t e r n a l Revenue Code of 1954 Ante, p. 1630. shall only apply to taxable years ending after December 31, 1975. (3) The amendment made by subsection (c) shall apply to taxable years beginning after June 29, 1976. (4) The amendments made by subsection (d) shall apply to taxes p a i d or accrued during taxable years ending after the date of the enactment of this Act. • - ' 'i SEC. 1036. UNDERWRITING INCOME. (a)
TREATMENT AS INCOME F R O M SOURCES W I T H I N THE UNITED
STATES.—Section 861(a) (relating to gross income from sources 26 USC 861. within the United States) is amended by a d d i n g the following new paragraph: " (7) Amounts received as underwriting income (as defined in section 832(b)(3)) derived from the insurance of United States risks (as defined in section 9 5 3 (a)). ". (b) TREATMENT AS FOREIGN SOURCE INCOME.—Section 862(a) (relat-
ing to gross income from sources without the United States) is 26 USC 862. amended by a d d i n g the following new paragraph: " (7) Under writing income other than that derived from sources within the United States as provided in section 861(a)(7). ". (c) ErrECTRTE D A T E. — The amendments made by this section shall 26 USC 861 a p p l y to taxable years beginning after December 31, 1976. note. SEC. 1037. THIRD TIER FOREIGN TAX CREDIT WHEN SECTION 951 APPLIES. (a)
FOREIGN TAXES D E E M E D P A I D BY FOREIGN
CORPORATIONS.—
Section 960(a)(1) (relating to special rules for foreign tax credits), as amended in section 1033, is further amended to read as follows: " (1) GENERAL RULE.—For purposes of subpart A of this part. if there is included, under section 9 5 1 (a), in the gross income of a domestic corporation any amount attributable to earnings and profits— " (A) of a foreign corporation (hereafter in this subsection referred to as the 'first foreign corporation') at least 10 per-
26 USC 960.
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