26 U.S.C. § 906 : US Code - Section 906: Nonresident alien individuals and foreign corporations

Search 26 U.S.C. § 906 : US Code - Section 906: Nonresident alien individuals and foreign corporations

(a) Allowance of credit
A nonresident alien individual or a foreign corporation engaged
in trade or business within the United States during the taxable
year shall be allowed a credit under section 901 for the amount of
any income, war profits, and excess profits taxes paid or accrued
during the taxable year (or deemed, under section 902, paid or
accrued during the taxable year) to any foreign country or
possession of the United States with respect to income effectively
connected with the conduct of a trade or business within the United
States.
(b) Special rules
(1) For purposes of subsection (a) and for purposes of
determining the deductions allowable under sections 873(a) and
882(c), in determining the amount of any tax paid or accrued to any
foreign country or possession there shall not be taken into account
any amount of tax to the extent the tax so paid or accrued is
imposed with respect to income from sources within the United
States which would not be taxed by such foreign country or
possession but for the fact that -
(A) in the case of a nonresident alien individual, such
individual is a citizen or resident of such foreign country or
possession, or
(B) in the case of a foreign corporation, such corporation was
created or organized under the law of such foreign country or
possession or is domiciled for tax purposes in such country or
possession.
(2) For purposes of subsection (a), in applying section 904 the
taxpayer's taxable income shall be treated as consisting only of
the taxable income effectively connected with the taxpayer's
conduct of a trade or business within the United States.
(3) The credit allowed pursuant to subsection (a) shall not be
allowed against any tax imposed by section 871(a) (relating to
income of nonresident alien individual not connected with United
States business) or 881 (relating to income of foreign corporations
not connected with United States business).
(4) For purposes of sections 902(a) and 78, a foreign corporation
choosing the benefits of this subpart which receives dividends
shall, with respect to such dividends, be treated as a domestic
corporation.
(5) No credit shall be allowed under this section for any income,
war profits, and excess profits taxes paid or accrued with respect
to the foreign trade income (within the meaning of section 923(b))
(!1) of a FSC.
(6) For purposes of section 902, any income, war profits, and
excess profits taxes paid or accrued (or deemed paid or accrued) to
any foreign country or possession of the United States with respect
to income effectively connected with the conduct of a trade or
business within the United States shall not be taken into account,
and any accumulated profits attributable to such income shall not
be taken into account.
(7) No credit shall be allowed under this section against the tax
imposed by section 884.