26 U.S.C. 904: Limitation on credit

2018

• Pub. L. 115–141, §401(d)(1)(D)(xiii), redesignated par. (5) as (4) and struck out former par. (4). Prior to amendment, text of par. (4) read as follows: "For purposes of subsection (a), in the case of a corporation, the taxable income shall not include any portion thereof taken… (Consolidated Appropriations Act, 2018) Law text · (b), (5)
• Pub. L. 115–141, §401(a)(157), inserted "subparagraph (E)(ii), or paragraph (3)(H)," after "Except as provided in clause (iii)," and struck out ", except as provided in subparagraph (E)(iii) or paragraph (3)(I)," after "includes". (Consolidated Appropriations Act, 2018) Law text · (d)
• Pub. L. 115–141, §401(d)(1)(D)(xiv), struck out "and section 936" after "subpart" in introductory provisions. (Consolidated Appropriations Act, 2018) Law text · (f)

2017

• Pub. L. 115–97, §13001(b)(2)(M)(i), struck out "or 1201(a)" after "under section 1(h)". Law text · (b)
• Pub. L. 115–97, §13001(b)(2)(M)(ii), added subpar. (D) and struck out former subpar. (D). Prior to amendment, text read as follows: "There is a capital gain rate differential for any taxable year if— Law text · (b)
• Pub. L. 115–97, §13001(b)(2)(M)(iii), added subpar. (E) and struck out former subpar. (E) which related to rate differential portion for corporations and taxpayers other than corporations. Law text · (b)
• Pub. L. 115–97, §14101(d), added par. (5). Law text · (b)
• Pub. L. 115–97, §14201(b)(2)(C), inserted at end "This subsection shall not apply to taxes paid or accrued with respect to amounts described in subsection (d)(1)(A)." Law text · (c)
• Pub. L. 115–97, §14201(b)(2)(A), added subpar. (A). Former subpar. (A) redesignated (B), then (C). Law text · (d)
• Pub. L. 115–97, §14302(a), added subpar. (B). Former subpar. (B) redesignated (C), then (D). Law text · (d)
• Pub. L. 115–97, §14201(b)(2)(A), redesignated subpar. (A) as (B). Former subpar. (B) redesignated (C). Law text · (d)
• Pub. L. 115–97, §14302(a), redesignated subpar. (B) as (C). Former subpar. (C) redesignated (D). Law text · (d)
• Pub. L. 115–97, §14201(b)(2)(A), redesignated subpar. (B) as (C). Law text · (d)
• Pub. L. 115–97, §14302(a), redesignated subpar. (C) as (D). Law text · (d)
• Pub. L. 115–97, §14302(b)(2), substituted "income described in paragraph (1)(A), foreign branch income, and" for "income described in paragraph (1)(A) and". Law text · (d)
• Pub. L. 115–97, §14201(b)(2)(B), inserted "income described in paragraph (1)(A) and" before "passive category income". Law text · (d)
• Pub. L. 115–97, §14301(c)(15)(A), amended cl. (i) generally. Prior to amendment, text read as follows: "The term 'noncontrolled section 902 corporation' means any foreign corporation with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (o… Law text · (d)
• Pub. L. 115–97, §14301(c)(15)(B), substituted "noncontrolled 10-percent owned foreign corporation" for "non-controlled section 902 corporation". Law text · (d)
• Pub. L. 115–97, §14302(b)(1), added subpar. (J). Law text · (d)
• Pub. L. 115–97, §14301(c)(16), substituted "noncontrolled 10-percent owned foreign corporations" for "noncontrolled section 902 corporations" in heading and "noncontrolled 10-percent owned foreign corporation" for "noncontrolled section 902 corporation" wherever appearing in text. Law text · (d)
• Pub. L. 115–97, §14301(c)(17), substituted "907" for "902, 907," in concluding provisions. Law text · (d)
• Pub. L. 115–97, §14304(a), added par. (5). Law text · (g)
• Pub. L. 115–97, §14301(c)(18), substituted "sections 907 and 960" for "sections 902, 907, and 960" in concluding provisions. Law text · (h)
• Pub. L. 115–97, §14301(c)(19), amended subsec. (k) generally. Prior to amendment, text read as follows: Law text · (k)

2014

• Pub. L. 113–295, §221(a)(72), struck out subpar. (J) which related to a transition rule for taxes paid or accrued in a taxable year beginning before Jan. 1, 1987. Law text · (d)
• Pub. L. 113–295, §219(c), struck out "as ordinary income under section 1246 or" after "gain treated". Law text · (h)

2013

• Pub. L. 112–240 redesignated subsecs. (j) to (l) as (i) to (k), respectively, and struck out former subsec. (i). Text read as follows: "In the case of any taxable year of an individual to which section 26(a)(2) does not apply, for purposes of subsection (a), the tax against whi… (American Taxpayer Relief Act of 2012) Law text · (i), (j), (k), (l)

2010

• Pub. L. 111–226, §213(a), added par. (6) and redesignated former par. (6) as (7). (______Act of____) Law text · (d), (7)
• Pub. L. 111–226, §217(c)(2), amended par. (9) generally. Prior to amendment, text read as follows: "For purposes of this subsection— (______Act of____) Law text · (h)
• Pub. L. 111–148, §10909(b)(2)(K), (c), as amended by Pub. L. 111–312, temporarily struck out "23," after "than sections". See Effective and Termination Dates of 2010 Amendment note below. (Patient Protection and Affordable Care Act) Law text · (i)

2009

• Pub. L. 111–5, §1144(b)(1)(E), inserted "30B," after "30". (American Recovery and Reinvestment Act of 2009) Law text · (i)
• Pub. L. 111–5, §1142(b)(1)(E), substituted "25B, 30, and 30D" for "and 25B". (American Recovery and Reinvestment Act of 2009) Law text · (i)
• Pub. L. 111–5, §1004(b)(5), inserted "25A(i)," after "24,". (American Recovery and Reinvestment Act of 2009) Law text · (i)

2007

• Pub. L. 110–172, §11(g)(10), inserted "and" at end of subcl. (I), redesignated subcl. (III) as (II), substituted "a former FSC (as defined in section 922)" for "a FSC (or a former FSC)" in subcl. (II), struck out former subcl. (II), which read as follows: "taxable income attri… (Tax Technical Corrections Act of 2007) Law text · (d)
• Pub. L. 110–172, §11(f)(3), substituted "an affiliated group" for "a controlled group". (Tax Technical Corrections Act of 2007) Law text · (f)

2005

• Pub. L. 109–135, §403(o), inserted "as in effect before its repeal" after "section 954(f)". (Gulf Opportunity Zone Act of 2005) Law text · (d)
• Pub. L. 109–135, §403(k), amended heading and text of par. (2) generally. Prior to amendment, text read as follows: "For purposes of this subsection— (Gulf Opportunity Zone Act of 2005) Law text · (g)
• Pub. L. 109–135, §402(i)(3)(G), reenacted heading without change and amended text generally. Prior to amendment, text read as follows: "In the case of an individual, for purposes of subsection (a), the tax against which the credit is taken is such tax reduced by the sum of the credits … (Gulf Opportunity Zone Act of 2005) Law text · (i)

2004

• Pub. L. 108–357, §417(a), struck out "in the second preceding taxable year," before "in the first preceding taxable year" and substituted "and in any of the first 10" for ", and in the first, second, third, fourth, or fifth". (American Jobs Creation Act of 2004) Law text · (c)
• Pub. L. 108–357, §404(a), reenacted heading without change and amended text of par. (1) generally, substituting provisions relating to applicability of subsecs. (a), (b), and (c) and sections 902, 907, and 960 to passive category income and general category income, for provisions re… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(1), struck out subpar. (E) which read as follows: "in the case of a corporation, dividends from noncontrolled section 902 corporations out of earnings and profits accumulated in taxable years beginning before January 1, 2003,". (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(b), added subpar. (A). Former subpar. (A) redesignated (B). (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §413(c)(14), reenacted heading without change and amended text of cl. (ii) generally. Prior to amendment, text read as follows: "Except as provided in clause (iii), the term 'passive income' includes any amount includible in gross income under section 551 or,… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(b), redesignated subpar. (A) as (B) and struck out former subpar. (B), which defined the term "high withholding tax interest". (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(f)(1), redesignated subcls. (II) and (III) as (I) and (II), respectively, and struck out former subcl. (I) which read as follows: "any income described in a subparagraph of paragraph (1) other than subparagraph (A),". (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(c), added cl. (v). (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(d), added subpar. (C). Former subpar. (C) redesignated (D). (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(2), inserted "and" at end of subcl. (I), redesignated subcl. (III) as (II), and struck out former subcl. (II) which read as follows: "any dividend from a noncontrolled section 902 corporation out of earnings and profits accumulated in taxable years b… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(d), redesignated subpar. (C) as (D) and struck out heading and text of former subpar. (D). Text read as follows: "The term 'shipping income' means any income received or accrued by any person which is of a kind which would be foreign base company shipping in… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(3), substituted "Such term does not include any financial services income" for "Such term does not include any dividend from a noncontrolled section 902 corporation out of earnings and profits accumulated in taxable years beginning before January 1, 2003 and does not includ… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(f)(2), inserted "or" at end of subcl. (I), added subcl. (II), and struck out former subcls. (II) and (III) which read as follows: (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(f)(3), which directed striking out of cl. (iii) "as so redesignated and amended by section 404(b)(3)", was executed by striking out heading and text of cl. (iii) as amended by section 403(b)(2) and redesignated by section 404(d), to reflect the probable… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(4)(A), inserted "or (4)" after "paragraph (3)". (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(4)(B), redesignated cl. (iii) as (ii) and struck out heading and text of former cl. (ii). Text read as follows: "If a foreign corporation is a noncontrolled section 902 corporation with respect to the taxpayer, taxes on high withholding tax int… (American Jobs Creation Act of 2004) Law text · (d), (iii)
• Pub. L. 108–357, §403(b)(4)(B), struck out heading and text of cl. (iv). Text read as follows: "All noncontrolled section 902 corporations which are not passive foreign investment companies (as defined in section 1297) shall be treated as one noncontrolled section 902 corpora… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(e), added subpar. (H) and redesignated former subpars. (H) and (I) as (I) and (J), respectively. (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(f)(5), added subpar. (K). (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §404(f)(4), reenacted heading without change and amended text of par. (3) generally, substituting provisions consisting of subpars. (A) to (H) for former subpars. (A) to (I) which contained similar provisions. (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(b)(5), substituted "or (D)" for "(D), or (E)". (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §403(a), reenacted heading without change and amended text of par. (4) generally, substituting provisions relating to dividends from noncontrolled section 902 corporations, earnings and profits of controlled foreign corporations, and setting forth special rules, for… (American Jobs Creation Act of 2004) Law text · (d)
• Pub. L. 108–357, §895(a), added subpar. (D). (American Jobs Creation Act of 2004) Law text · (f)
• Pub. L. 108–357, §402(a), added subsec. (g). Former subsec. (g) redesignated (h). (American Jobs Creation Act of 2004) Law text · (g)
• Pub. L. 108–357, §402(a), redesignated subsec. (g) as (h). Former subsec. (h) redesignated (i). (American Jobs Creation Act of 2004) Law text · (h)
• Pub. L. 108–311 substituted "2003, 2004, or 2005" for "or 2003". (Working Families Tax Relief Act of 2004) Law text · (h)
• Pub. L. 108–357, §413(c)(15)(A), inserted "or" at end of cl. (i), redesignated cl. (iii) as (ii), and struck out former cl. (ii) which read as follows: "section 551 (relating to foreign personal holding company income taxed to United States shareholders), or". (American Jobs Creation Act of 2004) Law text · (h)
• Pub. L. 108–357, §413(c)(15)(B), struck out "foreign personal holding or" before "passive foreign investment" in heading. (American Jobs Creation Act of 2004) Law text · (h)
• Pub. L. 108–357, §402(a), redesignated subsecs. (h) and (i) as (i) and (j), respectively. Former subsec. (j) redesignated (k). (American Jobs Creation Act of 2004) Law text · (i), (j)
• Pub. L. 108–357, §402(a), redesignated subsec. (j) as (k). Former subsec. (k) redesignated (l). (American Jobs Creation Act of 2004) Law text · (k)
• Pub. L. 108–357, §404(f)(6), which directed amendment of subsec. (j)(3)(A)(i) by substituting "subsection (d)(2)(B)" for "subsection (d)(2)(A)", was executed to subsec. (k)(3)(A)(i) to reflect the probable intent of Congress and the amendment by Pub. L. 108–357, §402(a). See a… (American Jobs Creation Act of 2004) Law text · (k)
• Pub. L. 108–357, §402(a), redesignated subsec. (k) as (l). (American Jobs Creation Act of 2004) Law text · (l)

2002

• Pub. L. 107–147, §601(b)(1), substituted "during 2000, 2001, 2002, or 2003" for "during 2000 or 2001". (Job Creation and Worker Assistance Act of 2002) Law text · (h)
• Pub. L. 107–147, §417(23)(B), amended directory language of Pub. L. 107–16, §618(b)(2)(D). See 2001 Amendment note below. (Job Creation and Worker Assistance Act of 2002) Law text · (h)

2001

• Pub. L. 107–16, §618(b)(2)(D), as amended by Pub. L. 107–147, §417(23)(B), substituted ", 24, and 25B" for "and 24". (Economic Growth and Tax Relief Reconciliation Act of 2001) Law text · (h)
• Pub. L. 107–16, §202(f)(2)(C), substituted "sections 23 and 24" for "section 24". (Economic Growth and Tax Relief Reconciliation Act of 2001) Law text · (h)
• Pub. L. 107–16, §201(b)(2)(G), inserted "(other than section 24)" after "chapter". (Economic Growth and Tax Relief Reconciliation Act of 2001) Law text · (h)

1999

• Pub. L. 106–170 inserted at end "This subsection shall not apply to taxable years beginning during 2000 or 2001." (Ticket to Work and Work Incentives Improvement Act of 1999) Law text · (h)

1997

• Pub. L. 105–34, §311(c)(3), added subpar. (C). (Taxpayer Relief Act of 1997) Law text · (b)
• Pub. L. 105–34, §1105(a)(1), amended subpar. (E) generally. Prior to amendment, subpar. (E) read as follows: "in the case of a corporation, dividends from each noncontrolled section 902 corporation,". (Taxpayer Relief Act of 1997) Law text · (d)
• Pub. L. 105–34, §1163(b), substituted "subclauses (I) and (III)" for "subclause (I)". (Taxpayer Relief Act of 1997) Law text · (d)
• Pub. L. 105–34, §1105(a)(3), inserted "out of earnings and profits accumulated in taxable years beginning before January 1, 2003" after "corporation". (Taxpayer Relief Act of 1997) Law text · (d), (D)
• Pub. L. 105–34, §1111(b), struck out "and except as provided in regulations, the taxpayer was a United States shareholder in such corporation" after "was a controlled foreign corporation". (Taxpayer Relief Act of 1997) Law text · (d)
• Pub. L. 105–34, §1105(a)(2), added cl. (iv). (Taxpayer Relief Act of 1997) Law text · (d)
• Pub. L. 105–34, §1105(b), added par. (4) and redesignated former pars. (4) and (5) as (5) and (6), respectively. (Taxpayer Relief Act of 1997) Law text · (d)
• Pub. L. 105–34, §1101(a), added subsec. (j) and redesignated former subsec. (j) as (k). (Taxpayer Relief Act of 1997) Law text · (j), (k)

1996

• Pub. L. 104–188, §1501(b)(1), (12), amended subpar. (G) identically, substituting "section 951(a)(1)(B)" for "subparagraph (B) or (C) of section 951(a)(1)". (Small Business Job Protection Act of 1996) Law text · (d)
• Pub. L. 104–188, §1703(i)(1), substituted "subparagraph (B) or (C) of section 951(a)(1)" for "section 951(a)(1)(B)". (Small Business Job Protection Act of 1996) Law text · (d)
• Pub. L. 104–188, §1704(t)(36), inserted "(as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990)" after "section 172(h)". (Small Business Job Protection Act of 1996) Law text · (f)

1993

• Pub. L. 103–66, §13227(d), inserted before period at end "(without regard to subsections (a)(4) and (i) thereof)". · (b)
• Pub. L. 103–66, §13235(a)(2), inserted "and" at end of subcl. II, substituted "income." for "income, and" in subcl. III, and struck out subcl. (IV) which read as follows: "any foreign oil and gas extraction income (as defined in section 907(c))." · (d)

1990

• Pub. L. 101–508, §11101(d)(5)(A), substituted "subsection (h)" for "subsection (j)". · (b)
• Pub. L. 101–508, §11101(d)(5)(B), substituted "section 1(h)" for "section 1(j)". · (b)
• Pub. L. 101–508, §11801(a)(31), struck out subsec. (e) which related to transitional rules for carrybacks and carryovers for taxpayers on the per-country limitation. · (e)

1989

• Pub. L. 101–239, §7811(i)(1), substituted "interest or carrying charges (as defined in section 927(d)(1)) derived from a transaction which results in foreign trade income (as defined in section 923(b))" for "qualified interest and carrying charges (as defined in section 245(c))". · (d)
• Pub. L. 101–239, §7402(a), added subsec. (i) and redesignated former subsec. (i) as (j). · (i), (j)

1988

• Pub. L. 100–647, §1003(b)(2)(A), amended par. (2) generally, substituting general provisions and provisions setting special rules where there is a capital gain rate differential for provisions for corporations and for other taxpayers. · (b)
• Pub. L. 100–647, §1003(b)(2)(B), added subpar. (D) and struck out former subpar. (D), Rate differential portion, which read as follows: "The 'rate differential portion' of foreign source net capital gain, net capital gain, or the excess of net capital gain from sources within the… · (b)
• Pub. L. 100–647, §2004(l), substituted "section 11(b)(1)" for "section 11(b)". · (b)
• Pub. L. 100–647, §1003(b)(2)(B), added subpar. (E). · (b)
• Pub. L. 100–647, §1012(a)(11), inserted "in the case of a corporation," before "dividends". · (d)
• Pub. L. 100–647, §1012(a)(6)(A), (p)(29)(A), substituted "Except as provided in clause (iii), the term" for "The term" and "or, except as provided in subparagraph (E)(iii) or paragraph (3)(I), section 1293" for "or section 1293". · (d)
• Pub. L. 100–647, §1012(a)(6)(B), added cl. (iv). · (d)
• Pub. L. 100–647, §1012(a)(8), amended cl. (iii) generally. Prior to amendment, cl. (iii) read as follows: "The Secretary may by regulations provide that amounts (not otherwise high withholding tax interest) shall be treated as high withholding tax interest where necessary to… · (d)
• Pub. L. 100–647, §1012(a)(1)(A), amended subpar. (C) generally, revising and restating as cls. (i) to (iii) provisions of former cls. (i) to (iv). · (d)
• Pub. L. 100–647, §1012(a)(2), provided for exclusion from term "shipping income" any dividend from a noncontrolled section 902 corporation and any financial services income. · (d)
• Pub. L. 100–647, §1012(a)(10), inserted "and except as provided in regulations, the taxpayer was a United States shareholder in such corporation" before period at end. · (d)
• Pub. L. 100–647, §1012(p)(29)(B), added cl. (iii). · (d)
• Pub. L. 100–647, §1012(a)(9), substituted "except that—" for "except to the extent that—", added subcls. (I) to (III), and struck out former subcls. (I) and (II) which read as follows: · (d)
• Pub. L. 100–647, §1012(a)(4), inserted first sentence, struck out former first sentence which read "If a controlled foreign corporation meets the requirements of section 954(b)(3)(A) (relating to de minimis rule) for any taxable year, for purposes of this paragraph, none of its i… · (d)
• Pub. L. 100–647, §1012(a)(7), amended subpar. (F) generally. Prior to amendment, subpar. (F) read as follows: "For purposes of this paragraph, the term 'separate category' means any category of income described in subparagraph (A), (B), (C), (D), or (E) of paragraph (1)." · (d)
• Pub. L. 100–647, §1012(a)(3), added subpar. (H). · (d)
• Pub. L. 100–647, §1012(p)(11), added subpar. (I). · (d)
• Pub. L. 100–647, §1012(c), added subpar. (F). · (f)
• Pub. L. 100–647, §1012(q)(12), substituted "861(a)(1)(A)" for "861(a)(1)(B)". · (g)
• Pub. L. 100–647, §1012(bb)(4)(A), added par. (10) and redesignated former par. (10) as (11). · (g), (11)

1986

• Pub. L. 99–514, §104(b)(13), struck out last sentence "For purposes of the preceding sentence, in the case of an individual the entire taxable income shall be reduced by an amount equal to the zero bracket amount." · (a)
• Pub. L. 99–514, §1211(b)(3), redesignated subpar. (E) as (C) and struck out former subpar. (C), exception for gain from the sale of certain personal property, which read as follows: "There shall be included as gain from sources within the United States any gain from sources witho… · (b)
• Pub. L. 99–514, §1211(b)(3), redesignated subpar. (F) as (D) and struck out former subpar. (D), gain from liquidation of certain foreign corporations, which read as follows: "Subparagraph (C) shall not apply with respect to a distribution in liquidation of a foreign corporation t… · (b)
• Pub. L. 99–514, §1211(b)(3), redesignated former subpars. (E) and (F) as (C) and (D), respectively. · (b), (F)
• Pub. L. 99–514, §1201(d)(1), substituted "certain categories of income" for "certain interest income and income from DISC, former DISC, FSC, or former FSC" in heading. · (d)
• Pub. L. 99–514, §1201(a), (d)(2), (3), inserted "and sections 902, 907, and 960" in introductory provisions, added subpars. (A) to (E), struck out former subpar. (A) which read "the interest income described in paragraph (2)", redesignated former subpars. (B), (C), (D), and (E) as (… · (d)
• Pub. L. 99–514, §1899A(24), made technical correction clarifying heading. See 1984 Amendment note below. · (d)
• Pub. L. 99–514, §1876(d)(2), amended subpar. (D) generally. Prior to amendment, subpar. (D) read as follows: "distributions from a FSC (or former FSC) out of earnings and profits attributable to foreign trade income (within the meaning of section 923(b)), and". · (d)
• Pub. L. 99–514, §1201(b), added par. (2) and struck out former par. (2), interest income to which applicable, which read as follows: "For purposes of this subsection, the interest income described in this paragraph is interest other than interest— · (d)
• Pub. L. 99–514, §1810(b)(3), inserted at end "For purposes of this subsection, interest (after the operation of section 904(d)(3)) received from a designated payor corporation described in section 904(d)(3)(E)(iii) by a taxpayer which owns directly or indirectly less than 10 percent of the voting s… · (d)
• Pub. L. 99–514, §1201(b), added par. (3) and struck out former par. (3) treating as interest certain amounts attributable to United States-owned foreign corporations, etc., subpars. thereof relating to following subject matter: (A) general provisions, (B) separate limitation interes… · (d)
• Pub. L. 99–514, §1810(b)(1), inserted at end "The preceding sentence shall not apply to any amount includible in gross income under section 551 or 951." · (d)
• Pub. L. 99–514, §1810(b)(4)(A), inserted at end: · (d)
• Pub. L. 99–514, §1810(b)(2), redesignated subpar. (I) as (J) and added a new subpar. (I), interest and dividends from members of same affiliated group, which read as follows: "For purposes of this paragraph, dividends and interest received or accrued by the designated payor corpo… · (d)
• Pub. L. 99–514, §1810(b)(2), redesignated subpar. (I) as (J) and struck out former subpar. (J), interest from members of same affiliated group, which read as follows: "For purposes of this paragraph, interest received or accrued by the designated payor corporation from another me… · (d)
• Pub. L. 99–514, §1201(b), added pars. (4) and (5). · (d), (5)
• Pub. L. 99–514, §1203(a), added par. (5). · (f)
• Pub. L. 99–514, §1235(f)(4)(A), added cl. (iii). · (g)
• Pub. L. 99–514, §1235(f)(4)(B), substituted "holding or passive foreign investment company" for "holding company" in heading. · (g)
• Pub. L. 99–514, §1810(a)(1)(A), added par. (9) and redesignated former par. (9) as (10). · (g), (10)
• Pub. L. 99–514, §701(e)(4)(H), struck out "by an individual" after "can be taken" and substituted "section 59(a)" for "section 55(c)". · (i)

1984

• Pub. L. 98–369, §801(d)(2)(C), which directed amendment of par. (1) heading by substituting "Separate application of section with respect to certain interest income and income from DISC, former DISC, FSC, or former FSC" for "Application of section in case of certain interest income and… · (d)
• Pub. L. 98–369, §801(d)(2)(A), (B), struck out "and" after "United States," at end of subpar. (B), substituted "taxable income attributable to foreign trade income (within the meaning of section 923(b))," for "income other than the interest income described in paragraph (2… · (d)
• Pub. L. 98–369, §122(a), added par. (3). · (d)
• Pub. L. 98–369, §121(a), added subsec. (g). Former subsec. (g) redesignated (h). · (g)
• Pub. L. 98–369, §474(r)(21), amended subsec. (g) generally, substituting "Coordination with nonrefundable personal credits" for "Coordination with credit for the elderly" in heading and in text substituting "reduced by the sum of the credits allowable under subpart A of part IV of subchapter A of t… · (g)
• Pub. L. 98–369, §121(a), redesignated former subsecs. (g) and (h) as (h) and (i), respectively. · (h), (i)

1983

• Pub. L. 98–21 substituted "relating to credit for the elderly and the permanently and totally disabled" for "relating to credit for the elderly". · (g)

1982

• Pub. L. 97–248 struck out par. (4) which provided for the determination of foreign oil related loss where section 907 was applicable, redesignated par. (5) as (4), and purported to redesignate par. (6) as (5). However, subsec. (f) did not contain a par. (6). · (f)

1980

• Pub. L. 96–222, §104(a)(3)(D)(i), redesignated subpar. (E) "Rate differential portion", added by Pub. L. 95–600, as (F). · (b)

1978

• Pub. L. 95–600, §§403(c)(4)(A), 701(u)(2)(A), (3)(A), in subpar. (A) substituted "this section" for "subsection (a)", "the rate differential portion" for "three eighths" wherever appearing, and "for purposes of determining taxable income from sources without the United States, any n… · (b)
• Pub. L. 95–600, §§403(c)(4)(B), 701(u)(2)(B), (C), as amended by Pub. L. 96–222, §104(a)(3)(D)(ii), substituted "There" for "For purposes of this paragraph, there", added subpar. (D), redesignated former subpar. (D), relating to section 1231 gains, as subpar. (E), and added another … · (b)
• Pub. L. 95–600, §701(u)(4)(A), struck out provision relating to capital loss carrybacks and carryovers. · (f)
• Pub. L. 95–600, §701(u)(4)(B), (8)(C), substituted in introductory provisions "In making the separate computation under this subsection with respect to foreign oil related income which is required by section 907(b)" for "In the case of a corporation to which section 907(b)(1) applie… · (f)
• Pub. L. 95–600, §701(q)(2), added par. (5). · (f)
• Pub. L. 95–600, §421(e)(6), designated existing provisions as par. (1) and added par. (2). · (h)

1977

• Pub. L. 95–30 provided that, for purposes of determining the maximum total amount of the credit taken under section 901(a), in the case of an individual, the entire taxable income shall be reduced by an amount equal to the zero bracket amount. · (a)

1976

• Pub. L. 94–455, §1031(a), struck out provisions allowing the per-country limitation, made the overall limitation applicable to all taxpayers to determine their foreign tax credit limitation, and inserted reference to section 901(a). · (a)
• Pub. L. 94–455, §§1031(a), 1034(a), 1051(e), redesignated subsec. (c) as (b)(1), inserted provisions that the net United States capital losses would offset net foreign capital gains and, in the case of corporations, that only 30/48 of the net foreign source gain would be included in th… · (b)
• Pub. L. 94–455, §1031(a), redesignated subsec. (d) as (c), and amended the redesignated subsec. (c) generally to conform to the elimination of the per-country limitation in subsec. (a). Former subsec. (c) redesignated (b)(1). · (c)
• Pub. L. 94–455, §1031(a), redesignated subsec. (f)(1), (2), as (d). Former subsec. (d) redesignated (c). · (d)
• Pub. L. 94–455, §1031(a), added subsec. (e). Former subsec. (e) was eliminated in view of the amendment of subsec. (a). · (e)
• Pub. L. 94–455, §§1031(a), 1032(a), 1901(b)(10)(B), added subsec. (f), and substituted "section 172(h)" for "section 172(k)(1)" in pars. (2)(B)(i) and (4)(B)(i). Former subsec. (f)(1), (2), was redesignated (d). Former subsecs. (f)(3), (4), (5) were omitted. · (f)
• Pub. L. 94–455, §§1032(a), 503(b)(1), added subsec. (g). Former subsec. (f) redesignated (g), and further redesignated (h). · (g)
• Pub. L. 94–455, §503(b)(1), redesignated former subsec. (g) as (h). · (h)

1971

• Pub. L. 92–178, §502(b)(2), inserted "and dividends from a DISC or former DISC" after "interest income" in the heading. · (f)
• Pub. L. 92–178, §502(b)(2), inserted "each of the following items of income" in introductory text, added subpar. (B), and redesignated former subpar. (B) as (C), inserting therein provisions respecting dividends described in subparagraph (B). · (f)
• Pub. L. 92–178, §502(b)(3), provided that the limitation provided by subsec. (a)(2) shall not apply to dividends described in paragraph (1)(B) and substituted "limitation provided by subsection (a)(2) applies with respect to income described in paragraph (1)(B) and (C)" for "limitat… · (f)
• Pub. L. 92–178, §502(b)(4), added par. (5). · (f)

1969

• Pub. L. 91–172, §506(b)(1), substituted "(A) with the consent of the Secretary or his delegate with respect to any taxable year or (B) for the taxpayer's first taxable year beginning after December 31, 1969" for "with the consent of the Secretary or his delegate with respect to any … · (b)
• Pub. L. 91–172, §506(b)(2), substituted "Except in a case to which paragraph (1)(B) applies, if the taxpayer" for "If a taxpayer". · (b)

1966

• Pub. L. 89–809 inserted reference to includible corporations in an affiliated group, as defined in section 1504, of which the taxpayer is a member and inserted reference to both direct and indirect ownership in subpar. (C) and inserted provision that, for purposes of subpar. (C), st… · (f)

1964

• Pub. L. 88–272 substituted "section 1503(b)" for "section 1503(d)". · (g)

1962

• Pub. L. 87–834, §10(a), added subsec. (f). Former subsec. (f) redesignated (g). · (f)
• Pub. L. 87–834, §§10(a), 12(b)(2), redesignated former subsec. (f) as (g), designated existing provisions as par. (2), and added par. (1). · (g)

1960

• Pub. L. 86–780, §1(a), designated existing provisions as par. (1), inserted introductory clause "In the case of any taxpayer who elects the limitation provided by this paragraph" and inserted "foreign", "or possession of the United States" and "or possession" therein and added par. (2). · (a)
• Pub. L. 86–780, §1(a), added subsec. (b). Former subsec. (b) redesignated (c). · (b)
• Pub. L. 86–780, §1(b), redesignated former subsec. (b) as (c) and inserted "applicable" before "limitation" therein. Former subsec. (c) redesignated (d). · (c)
• Pub. L. 86–780, §1(c), redesignated former subsec. (c) as (d) and inserted "applicable" before "limitation" in two places. · (d)
• Pub. L. 86–780, §1(d), added subsecs. (e) and (f). · (e), (f)

1958

• Pub. L. 85–866 added subsec. (c). · (c)