§ 78. Gross up for deemed paid foreign tax credit
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/usc/title-26/section-78A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under subsections
(a)and
(d)of section 960 (determined without regard to the phrase “90 percent of” in subsection (d)(1) thereof) for such taxable year shall be treated for purposes of this title (other than sections 245 and 245A) as a dividend received by such domestic corporation from the foreign corporation.
(Added Pub. L. 87–834, § 9(b), Oct. 16, 1962, 76 Stat. 1001; amended Pub. L. 94–455, title X, § 1033(b)(1), Oct. 4, 1976, 90 Stat. 1628; Pub. L. 115–97, title I, § 14301(c)(1), Dec. 22, 2017, 131 Stat. 2222; Pub. L. 119–21, title VII, § 70312(a)(2), July 4, 2025, 139 Stat. 203.)
Connections30 cite this · traces to 4
Cited by 30 sections · top 24
public-private-law
U.S. Code
- § 861Income from sources within the United States
- § 904Limitation on credit
- § 901Taxes of foreign countries and of possessions of United States
- § 245Dividends received from certain foreign corporations
- § 865Source rules for personal property sales
- § 902Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221]
- § 6038Information reporting with respect to certain foreign corporations and partnerships
- § 535Accumulated taxable income
- § 1291Interest on tax deferral
- § 960Deemed paid credit for subpart F inclusions
- § 907Special rules in case of foreign oil and gas income
- § 958Rules for determining stock ownership
- § 545Undistributed personal holding company income
- § 905Applicable rules
- § 959Exclusion from gross income of previously taxed earnings and profits
- § 908Reduction of credit for participation in or cooperation with an international boycott
- § 909Suspension of taxes and credits until related income taken into account
- § 1293Current taxation of income from qualified electing funds
- § 906Nonresident alien individuals and foreign corporations
- § 814Contiguous country branches of domestic life insurance companies
Traces to 4 documents
public-private-law
10 references not yet in our index
- Pub. L. 87–834, § 9(b)
- 76 Stat. 1001
- Pub. L. 94–455, title X, § 1033(b)(1)
- 90 Stat. 1628
- 131 Stat. 2222
- 139 Stat. 203
- Pub. L. 94–455
- 131 Stat. 2225
- section 1033(c) of Pub. L. 94–455
- Pub. L. 87–834, § 9(e)
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cites case law
§ 78
Gross up for deemed paid foreign tax credit
U.S.C.×24
Pub. L.×3
Stat.×3
Pub. L.Pub. L. 87–834, § 9(b)
Stat.76 Stat. 1001
Pub. L.Pub. L. 94–455, title X, § 1033(b)(1)
Stat.90 Stat. 1628
Stat.131 Stat. 2222
Cites 14 · showing 9Cited by 30 across 3 sources