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.
(Added Sept. 1, 1954, ch. 1206, title II, 210(a), 68 Stat. 1096.)
BACKGROUND NOTES
[177. Repealed. Pub. L. 99-514, title II, 241(a), Oct. 22, 1986, 100 Stat. 2181]
Section, added June 29, 1956, ch. 464, 4(a), 70 Stat. 406, and amended Oct. 4, 1976,
Pub. L. 94-455, title XIX, 1906(b)(13)(A), 90 Stat. 1834, related to deductions for trademark and
trade name expenditures.
Effective Date of Repeal
Section 241(c) of Pub. L. 99-514 provided that:
“(1) In general.--Except as provided in paragraph
(2), the amendments made by this section [amending sections 312 and 1016 of this title
and repealing this section] shall apply to expenditures paid or incurred after December
31, 1986.
“(2) Transitional rule.--The amendments made by this section shall not apply to any
expenditure incurred--
“(A) pursuant to a binding contract entered into before March 2, 1986, or
“(B) with respect to the development, protection, expansion, registration, or defense
of a trademark or trade name commenced before March 2, 1986, but only if not less
than the lesser of $1,000,000 or 5 percent of the aggregate cost of such development,
protection, expansion, registration, or defense has been incurred or committed before
such date.
The preceding sentence shall not apply to any expenditure with respect to a trademark
or trade name placed in service after December 31, 1987.”
