1010
PUBLIC LAW 86-780-SEPT. U, 1960
[74 S T A T.
pwbeVs" local Ec. 11. The Pensioii Fund, Plumbers' Local Union Numbered 775, Union Numbered which was Created May 1, 1957, as a result of an agreement between "*• Plumbers' Local Union Numbered 775, of Suffolk County, New York, affiliated with the United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of the United States and Canada, and the Suffolk County Plumbing and Heating Contractors Association, Inc.j and which has been held by the Internal Revenue Service to constitute a qualified trust under section 401(a) of the 26 USC 401. Internal Revenue Code of 1954, and to be exempt from taxation under 26 USC sou section 501(a) of such Code, shall be held and considered to have been a qualified trust under such section 401(a), and to have been exempt from taxation under such section 501(a), for the period beginning May 1, 1957, and ending May 11, 1959, but only if it is shown to the satisfaction of the Secretary of the Treasury or his delegate that the trust has not in this period been operated in a manner which would jeopardize the interests of its beneficiaries. Approved September 14, 1960.
Public Law 86-780 September 14, 1960 JH
R
—LJ—I
100871
ANACT
i— To amend the Internal Revenue Code of 1954 to permit taxpayers to elect an overall limitation on the foreign tax credit.
Be it enacted by the Senate and House of Representatives of the United /States of America in Congress assembled, That (a) section 904 Foreign tax gf ^he Internal Revenue Code of 1954 (relating to limitation on for'^'esA Stat. 287. ^^^ tax Credit) is amended by striking out subsection (a) and insert26 USC 904. ing in lieu thereof the following new subsections: I R e 1954, mendment
' (a) ALTERNATIVE LIMITATIONS.— "(1) PER-COUNTRY LIMITATION.—In the case of any taxpayer
who does not elect the limitation provided by paragraph (2), the amount of the credit in respect of the tax paid or accrued to any foreign country or possession of the United States shall not exceed the same proportion of the tax against which such credit is taken which the taxpayer's taxable income from sources within such country or possession (but not in excess of the taxpayer's entire taxable income) bears to his entire taxable income for the same taxable year. "(2) OVERALL LIMITATION.—In the case of any taxpayer who elects the limitation provided by this paragraph, the total amount of the credit in respect of taxes paid or accrued to all foreign countries and possessions of the United States shall not exceed the same proportion of the tax against which such credit is taken which the taxpayer's taxable income from sources without the United States (but not in excess of the taxpayer's entire taxable income) bears to his entire taxable income for the same taxable year. " (b) ELECTION OF OVERALL LIMITATION.—
"(1) IN GENERAL.—A taxpayer may elect the limitation provided by subsection (a)(2) for any taxable year beginning after December 31. 1960. An election under this paragraph for any taxable year shall remain in effect for all subsequent taxable years, except that it may be revoked with the consent of the Secretary or his delegate with respect to any taxable year.
�
