1006
Ante. p. 1005.
PUBLIC LAW 8 7 - 8 3 4 - O C T. 16, 1962
[76 STAT.
(A) received after March 12, 1962, which are attributable to services performed after December 31, 1962, or (B) received after December 31, 1962, which are attributable to services performed on or befqre December 31, 1962, unless on March 12, 1962, there existed a right (whether forfeitable or nonforfeitable) to receive such amounts. ^2) AMENDMENT TO SECTION 72(f)-.—The amendment made by subsection (b) shall apply to taxable years ending after December 31, 1962.
SEC. 12. CONTROLLED FOREIGN CORPORATIONS. 26 USC 901 et
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(a) IN GENERAL.—Part III of subchapter N of chapter 1 (relating to income from sources without the United States) is amended by adding at the end thereof the following new subparts: "Subpart F—Controlled Foreign Corporations "Sec. 951. Amounts included in gross income of United States shareholders. "Sec. 952. Subpart F income defined. "Sec. 953. Income from insurance of United States rislcs. "Sec. 954. Foreign base company income. "Sec. 955. Withdrawal of previously excluded subpart F income from qualified investment. "Sec. 956. Investment of earnings in United States property. "Sec. 957. Controlled foreign corix>rations; United States persons. "Sec. 958. Rules for determining stock ownership. "Sec. 959. Exclusion from gross income of previously taxed earnings and profits. "Sec. 960. Special rules for foreign tax credit. "Sec. 961. Adjustments to basis of stock in controlled foreign corporations and of other property. "Sec. 962. Election by individuals to be subject to tax at corporate rates. "Sec. 963. Receipt of minimum distributions by domestic corporations. "Sec. 964. Miscellaneous provisions. "SEC. 951. AMOUNTS INCLUDED IN GROSS INCOME OF UNITED STATES SHAREHOLDERS. "(a)
Post, p. 1018.
Post, p. 1023.
Post, p. 1016. Poet, p. 1019.
AMOUNTS INCLUDED.—
"(1) IN GENERAL.—If a foreign corporation is a controlled foreign corporation for an uninterrupted period of 30 days or more during any taxable year beginning after December 31, 1962, every person who is a United States shareholder (as defined in subsection (b)) of such corporation and who owns (within the meaning of section 958(a)) stock in such corporation on the last day, in such year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends— " (A) the sum of— " (i) except as provided in section 963, his pro rata share (determined under paragraph (2)) of the corporation's subpart F income for such year, ana "(ii) his pro rata share (determined under section 955 (a)(3)) of the corporation's previously excluded subpart F income withdrawn from investment in less developed countries for such year; and " (B) his pro rata share (determined under section 956 (a)(2)) of the corporation's increase in earnings invested in United States property for such year (but only to the extent not excluded from gross income under section 959(a)(2)). "(2) PRO RATA SHARE OF SUBPART F INCOME.—The pro rata share referred to in paragraph (l)(A)(i) in the case of any United States shareholder is the amount— ,,,,-> v.• -ra*^
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