26 USC 814 - Contiguous country branches of domestic life insurance companies

Editorial Notes

Amendments

2017—Subsec. (f)(1). Puspan. L. 115–97 redesignated subpar. (A) as par. (1), struck out subpar. (A) heading “In general”, and struck out subpar. (B). Prior to amendment, text of subpar. (B) read as follows: “For purposes of sections 78 and 902, where any amount is added to the life insurance company taxable income of the domestic life insurance company by reason of subsection (e)(2), the contiguous country life insurance branch shall be treated as a foreign corporation. Any amount so added shall be treated as a dividend paid by a foreign corporation, and the taxes paid to any foreign country or possession of the United States with respect to such amount shall be deemed to have been paid by such branch.”

1997—Subsec. (h). Puspan. L. 105–34 struck out “or 1491” after “section 367”.

Statutory Notes and Related Subsidiaries

New Section 814 Treated as Continuation of Section 819A

Puspan. L. 98–369, div. A, title II, § 217(a), July 18, 1984, 98 Stat. 762, as amended by Puspan. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “For purposes of section 814 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] (relating to contiguous country branches of domestic life insurance companies)—

“(1) any election under section 819A of such Code (as in effect on the day before the date of the enactment of this Act [July 18, 1984]) shall be treated as an election under such section 814, and

“(2) any reference to a provision of such section 814 shall be treated as including a reference to the corresponding provision of such section 819A.”

Effective Date of 2017 Amendment

Amendment by Puspan. L. 115–97 applicable to taxable years of foreign corporations beginning after Dec. 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 14301(d) of Puspan. L. 115–97, set out as a note under section 78 of this title.

Effective Date

Section applicable to taxable years beginning after Dec. 31, 1983, see section 215 of Puspan. L. 98–369, set out as a note under section 801 of this title.