...paid by such foreign corporation to any foreign country or to any possession of the TTnited States, 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...

...income tax paid or deemed to have been 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...

...country or to any possession of the United States, on or with respect to such accumulated profits, which the amount of such dividends bears to the amount of such accumulated profits. The general intent of section 902 of the Code and the underlying assumption of the icgulations thereunder...

...paid, which the amount of sue dividends bears to the amount of such accumulated profits: Provided, That amount of tax deemed to have been paid under this subsection shall in no i exceed the same proportion of the tax against which credit is taken which ttrd amount of such dividends...

...or deemed to be paid by such foreign corporation to any foreign country on such accumulated profits, which the amount of such dividends bears to the amount of such accumulated profits. Section 963 of the Code operates in conjunction with section 951. Section 951 (a) (1) (A) (i), in pertinent...

...profits, or excess profits taxes paid to any foreign country or to any possession of the United States, on the interest of a deceased partner made to his surviving spouse. See Rev. Rul. 71-507, distribution is made, which were not deemed paid by the domestic corporation under paragraph (1) for...

...this approach since the Revenue Act of 1921, under which the credit was allowed for taxes Imposed on "or with respect to the accumulated profits of such...corporation from which such dividends were paid." (Emphasis supplied.) Sec. 240(e). Revenue Act of 1921, 42 Stnt. 259. Cf. American Chicle Co. v. United...

...have paid the same proportion of foreign taxes paid "on or with respect to such accumulated profits, which the amount of such dividends * * * bears to the amount of such accumulated profits in excess of such [foreign taxes]." (Emphasis added.) The repeated reference to "such accumulated profits...

...section 902(a) and (c)(l), which we have italicized, see supra pp. 415-416, relates the taxes paid to "the accumulated profits of such foreign corporation from which such dividends were paid" (sec. 902(a)) and specifies that "accumulated profits" should be determined without reduction by the...

...this approach since the Revenue Act of 1921, under which the credit was allowed for taxes imposed on "or with respect to the accumulated profits of such...corporation from which such dividends were paid." (Emphasis supplied.) Sec. 240(e), Revenue Act of 1921, 42 Stat. 259. Cf. American Chicle Co. v. United...