26 U.S.C. § 78
Gross up for deemed paid foreign tax credit
If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under subsections (a) and (d) of section 960 (determined without regard to the phrase “90 percent of” in subsection (d)(1) thereof) for such taxable year shall be treated for purposes of this title (other than sections 245 and 245A) as a dividend received by such domestic corporation from the foreign corporation.
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Cited by 47
- 26 CFR § 1.1248-1 — Treatment of gain from certain sales or exchanges of stock in certain foreign corporations.
- 26 CFR § 1.1502-32 — Investment adjustments.
- 26 CFR § 1.1502-50 — Consolidated section 250.
- 26 CFR § 1.1503(d)-5 — Attribution of items and basis adjustments.
- 26 CFR § 1.1503(d)-7 — Examples.
- 26 CFR § 1.163(j)-1 — Definitions.
- 26 CFR § 1.250(a)-1 — Deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).
- 26 CFR § 1.250(b)-1 — Computation of foreign-derived intangible income (FDII).
- 26 CFR § 1.367(b)-7 — Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.
- 26 CFR § 1.535-2 — Adjustments to taxable income.
- 26 CFR § 1.545-2 — Adjustments to taxable income.
- 26 CFR § 1.6038-2 — Information returns required of United States persons with respect to annual accounting periods of certain foreign corporations.
Show 35 more
- 26 CFR § 1.78-1 — Gross up for deemed paid foreign tax credit.
- 26 CFR § 1.7874-11 — Rules regarding inversion gain.
- 26 CFR § 1.861-3 — Dividends and income inclusions under sections 951, 951A, and 1293 and associated section 78 dividends.
- 26 CFR § 1.861-8 — Computation of taxable income from sources within the United States and from other sources and activities.
- 26 CFR § 1.865-2 — Loss with respect to stock.
- 26 CFR § 1.897-9T — Treatment of certain interest in publicly traded corporations, definition of foreign person, and foreign governments and international organizations (temporary).
- 26 CFR § 1.901(m)-3 — Disqualified tax amount and aggregate basis difference carryover.
- 26 CFR § 1.901-3 — Reduction in amount of foreign taxes on foreign mineral income allowed as a credit.
- 26 CFR § 1.902-0 — Outline of regulations provisions for section 902.
- 26 CFR § 1.902-1 — Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation.
- 26 CFR § 1.902-2 — Treatment of deficits in post-1986 undistributed earnings and pre-1987 accumulated profits of a first- or lower-tier corporation for purposes of computing an amount of foreign taxes deemed paid under § 1.902-1.
- 26 CFR § 1.902-3 — Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before January 1, 1987.
- 26 CFR § 1.902-4 — Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation.
- 26 CFR § 1.904-4 — Separate application of section 904 with respect to certain categories of income.
- 26 CFR § 1.904-5 — Look-through rules as applied to controlled foreign corporations and other entities.
- 26 CFR § 1.905-1 — When credit for foreign income taxes may be taken.
- 26 CFR § 1.905-3 — Adjustments to U.S. tax liability and to current earnings and profits as a result of a foreign tax redetermination.
- 26 CFR § 1.907(a)-1 — Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
- 26 CFR § 1.907(c)-2 — Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
- 26 CFR § 1.907(c)-3 — FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).
- 26 CFR § 1.907-0 — Outline of regulation provisions for section 907.
- 26 CFR § 1.951-1 — Amounts included in gross income of United States shareholders.
- 26 CFR § 1.960-4 — Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
- 26 CFR § 1.960-6 — Overpayments resulting from increase in limitation for taxable year of exclusion.
- 26 CFR § 1.961-1 — Increase in basis of stock in controlled foreign corporations and of other property.
- 26 CFR § 1.962-1 — Limitation of tax for individuals on amounts included in gross income under section 951(a).
- 26 CFR § 1.963-2 — Determination of the amount of the minimum distribution.
- 26 CFR § 1.965-0 — Outline of section 965 regulations.
- 26 CFR § 1.965-5 — Allowance of credit or deduction for foreign income taxes.
- 26 CFR § 1.965-7 — Elections, payment, and other special rules.
- 26 U.S.C. § 1291 — Interest on tax deferral
- 26 U.S.C. § 250 — Foreign-derived deduction eligible income and net CFC tested income
- 26 U.S.C. § 904 — Limitation on credit
- 26 U.S.C. § 908 — Reduction of credit for participation in or cooperation with an international boycott
- 26 U.S.C. § 965 — Treatment of deferred foreign income upon transition to participation exemption system of taxation
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