I.R.C. § 908(a) In General
If a person, or a member of a controlled group (within the meaning of section 993(a)(3)
) which includes such person, participates in or cooperates with an international
boycott during the taxable year (within the meaning of section 999(b)
), the amount of the credit allowable under section 901
such person, or under section 960
to United States shareholders of such person, for foreign taxes paid during the
taxable year shall be reduced by an amount equal to the product of—
I.R.C. § 908(a)(1)
the amount of the credit which, but for this section, would be allowed under section
for the taxable year, multiplied by
I.R.C. § 908(b) Application With Sections 275(a)(4) And 78
and section 78
shall not apply to any amount of taxes denied credit under subsection (a).
(Added Pub. L. 94-455, title X, 1061(a), Oct. 4, 1976, 90 Stat. 1649; amended by Pub. L. 115-97, title I, Sec. 14301(c)(28), Dec. 22, 2017, 131 Stat. 2054.)
2017—Subsec. (a). Pub. L. 115-97, Sec. 14301(c)(28), amended subsec. (a) by striking “or 902”.
EFFECTIVE DATE OF 2017 AMENDMENT
Section 14301(c)(28) of Pub. L. 115-97 effective for taxable years of foreign corporations beginning after December 31,
2017, and for taxable years of United States shareholders in which or with which such
taxable years of foreign corporations end.
Section 1066(a) of Pub. L. 94-455 provided that:
“(1) General rule.--The amendments made by this part (other than by section
1065) [enacting this section and section 999 of this title and amending sections 952
and 995 of this title]
apply to participation in or cooperation with an international boycott more than 30
days after the date of enactment of this Act [Oct. 4, 1976].
“(2) Existing contracts.--In the case of operations which constitute participation
in or cooperation with an international boycott and which are carried out in accordance
with the terms of a binding contract entered into before September 2, 1976, the amendments
made by this part (other than by section 1065) apply to such participation or cooperation
after December 31, 1977.”