26 U.S.C. § 1358 : US Code - Section 1358: Allocation of credits, income, and deductions

Search 26 U.S.C. § 1358 : US Code - Section 1358: Allocation of credits, income, and deductions

(a) Qualifying shipping activities
For purposes of this chapter, the qualifying shipping activities
of an electing corporation shall be treated as a separate trade or
business activity distinct from all other activities conducted by
such corporation.
(b) Exclusion of credits or deductions
(1) No deduction shall be allowed against the notional shipping
income of an electing corporation, and no credit shall be allowed
against the tax imposed by section 1352(a)(2).(!1)
(2) No deduction shall be allowed for any net operating loss
attributable to the qualifying shipping activities of any person to
the extent that such loss is carried forward by such person from a
taxable year preceding the first taxable year for which such person
was an electing corporation.
(c) Transactions not at arm's length
Section 482 applies in accordance with this subsection to a
transaction or series of transactions -
(1) as between an electing corporation and another person, or
(2) as between an (!2) person's qualifying shipping activities
and other activities carried on by it.