 | United States. Congress. House. Committee on Ways and Means - 1960 - 90 pages
...Subsections (a) and (b) of section 902 of the Internal Revenue Code of 1954 are each amended by striking out "which the amount of such dividends bears to the amount of such accumulated profits" and inserting in lieu thereof "which the amount of such dividends (determined without regard to subsection... | |
 | United States, United States. Congress. Joint Committee on Internal Revenue Taxation - 1961 - 1208 pages
...such foreign corporation to any foreign country or to any possession of the United States, on or witn respect to the accumulated profits of such foreign...dividends bears to the amount of such accumulated profits. (b) FOREIGN SUBSIDIARY OP FOREIGN CORPORATION. — If such foreign corporation owns 50 percent or more... | |
 | United States. Congress. Senate. Committee on Finance - 1962 - 1730 pages
...excess profits taxes (other than those deemed paid) ". (B) Section 902(b) is amended by striking out "which the amount of such dividends bears to the amount of such accumulated profits" and inserting in lieu thereof "which the amount of such dividends bears to the amount of such accumulated... | |
 | United States. Congress. Senate. Committee on Finance - 1962 - 754 pages
...profits, or excess profits taxes paid to any foreign country or to any possession of the United States, on or with respect to the accumulated profits of such foreign corporation from which such distribution is made, which were not deemed paid by the domestic corporation under paragraph (1) for... | |
 | United States. Congress. House. Committee on Ways and Means - 1967 - 1468 pages
...profits, or excess profits taxes paid to any foreign country or to any possession of the United States, on or with respect to the accumulated profits of such foreign corporation from which such distribution is made, which were not deemed paid by the domestic corporation under paragraph (1) for... | |
 | United States. Tax Court - 1956 - 1226 pages
...paid by such foreign corporation to any foreign country or to any possession of the T'nlted States, upon or with respect to the accumulated profits of...dividends bears to the amount of such accumulated profits. The term "accumulated profits" when used In this subsection In reference to a foreign corporation,... | |
 | United States. Internal Revenue Service - 1977
...of any income taxes paid or deemed to be paid by such foreign corporation to any foreign country, on he amount specified in clause (i) or (ii) of in excess of such income taxes. Section 902 (b) of the Code provides, in part, that if a first-tier... | |
 | United States. Internal Revenue Service - 1979 - 664 pages
...or excess profits taxes paid or deemed paid by such foreign corporation to any foreign country, on or with respect to the accumulated profits of such...dividends were paid, which the amount of such dividends (determined without regard to section 78) bears to the amount of such accumulated profits in excess... | |
| |
... taxes paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends... 
