26 U.S.C. § 176 : US Code - Section 176: Payments with respect to employees of certain foreign corporations

Search 26 U.S.C. § 176 : US Code - Section 176: Payments with respect to employees of certain foreign corporations

In the case of a domestic corporation, there shall be allowed as
a deduction amounts (to the extent not compensated for) paid or
incurred pursuant to an agreement entered into under section
3121(l) with respect to services performed by United States
citizens employed by foreign subsidiary corporations. Any
reimbursement of any amount previously allowed as a deduction under
this section shall be included in gross income for the taxable year
in which received.