26 USC 853 - Foreign tax credit allowed to shareholders

Editorial Notes

Amendments

2010—Subsec. (c). Puspan. L. 111–325, § 301(c)(1)(B), substituted “Statements” for “Notice” in heading.

Puspan. L. 111–325, § 301(c)(1)(A), which directed amendment by substituting “so reported by the company in a written statement furnished to such shareholder” for “so designated by the company in a written notice mailed to its shareholders not later than 60 days after the close of the taxable year”, was executed by making the substitution for “so designated by the company in a written notice mailed to its shareholders not later than 60 days after the close of its taxable year” in concluding provisions to reflect the probable intent of Congress.

Subsec. (d). Puspan. L. 111–325, § 301(c)(2), struck out “and notifying shareholders” after “election” in heading and “and the notice to shareholders required by subsection (c)” after “subsection (a)” in text.

2005—Subsec. (e). Puspan. L. 109–135 amended heading and text of subsec. (e) generally. Prior to amendment, text read as follows: “This section shall not apply to any tax with respect to which the regulated investment company is not allowed a credit under section 901 by reason of section 901(k).”

1998—Subsec. (c). Puspan. L. 105–206, § 6010(k)(2), struck out at end “Such notice shall also include the amount of such taxes which (without regard to the election under this section) would not be allowable as a credit under section 901(a) to the regulated investment company by reason of section 901(k).”

Subsecs. (e), (f). Puspan. L. 105–206, § 6010(k)(1), added subsec. (e) and redesignated former subsec. (e) as (f).

1997—Subsec. (c). Puspan. L. 105–34 inserted at end “Such notice shall also include the amount of such taxes which (without regard to the election under this section) would not be allowable as a credit under section 901(a) to the regulated investment company by reason of section 901(k).”

1986—Subsec. (c). Puspan. L. 99–514 substituted “60 days” for “45 days”.

1976—Subsec. (d). Puspan. L. 94–455 struck out “or his delegate” after “Secretary”.

1964—Subsec. (c). Puspan. L. 88–272 substituted “45 days” for “30 days”.

Statutory Notes and Related Subsidiaries

Effective Date of 2010 Amendment

Amendment by Puspan. L. 111–325 applicable to taxable years beginning after Dec. 22, 2010, see section 301(h) of Puspan. L. 111–325, set out as a note under section 852 of this title.

Effective Date of 2005 Amendment

Amendment by Puspan. L. 109–135 effective as if included in the provision of the American Jobs Creation Act of 2004, Puspan. L. 108–357, to which such amendment relates, see section 403(nn) of Puspan. L. 109–135, set out as a note under section 26 of this title.

Effective Date of 1998 Amendment

Amendment by Puspan. L. 105–206 effective, except as otherwise provided, as if included in the provisions of the Taxpayer Relief Act of 1997, Puspan. L. 105–34, to which such amendment relates, see section 6024 of Puspan. L. 105–206, set out as a note under section 1 of this title.

Effective Date of 1997 Amendment

Puspan. L. 105–34, title X, § 1053(c), Aug. 5, 1997, 111 Stat. 943, provided that:

“The amendments made by this section [amending this section and section 901 of this title] shall apply to dividends paid or accrued more than 30 days after the date of the enactment of this Act [Aug. 5, 1997].”

Effective Date of 1986 Amendment

Amendment by Puspan. L. 99–514 applicable to taxable years beginning after Oct. 22, 1986, see section 655(span) of Puspan. L. 99–514, set out as a note under section 852 of this title.

Effective Date of 1964 Amendment

Amendment by Puspan. L. 88–272 applicable to taxable years of regulated investment companies ending on or after Fespan. 26, 1964, see section 229(c) of Puspan. L. 88–272, set out as a note under section 852 of this title.