26 U.S.C. § 1353 : US Code - Section 1353: Notional shipping income
Search 26 U.S.C. § 1353 : US Code - Section 1353: Notional shipping income
(a) In general
For purposes of this subchapter, the notional shipping income of
an electing corporation shall be the sum of the amounts determined
under subsection (b) for each qualifying vessel operated by such
electing corporation.
(b) Amounts
(1) In general
For purposes of subsection (a), the amount of notional shipping
income of an electing corporation for each qualifying vessel for
the taxable year shall equal the product of -
(A) the daily notional shipping income, and
(B) the number of days during the taxable year that the
electing corporation operated such vessel as a qualifying
vessel in United States foreign trade.
(2) Treatment of vessels the income from which is not otherwise
subject to tax
In the case of a qualifying vessel any of the income from which
is not included in gross income by reason of section 883 or
otherwise, the amount of notional shipping income from such
vessel for the taxable year shall be the amount which bears the
same ratio to such shipping income (determined without regard to
this paragraph) as the gross income from the operation of such
vessel in the United States foreign trade bears to the sum of
such gross income and the income so excluded.
(c) Daily notional shipping income
For purposes of subsection (b), the daily notional shipping
income from the operation of a qualifying vessel is -
(1) 40 cents for each 100 tons of so much of the net tonnage of
the vessel as does not exceed 25,000 net tons, and
(2) 20 cents for each 100 tons of so much of the net tonnage of
the vessel as exceeds 25,000 net tons.
(d) Multiple operators of vessel
If for any period 2 or more persons are operators of a qualifying
vessel, the notional shipping income from the operation of such
vessel for such period shall be allocated among such persons on the
basis of their respective ownership, charter, and operating
agreement interests in such vessel or on such other basis as the
Secretary may prescribe by regulations.
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Alternative tax election; revocation; termination