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Sec. 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.
(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 Repealed.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.”