26 U.S.C. § 78
§ 78. Gross up for deemed paid foreign tax credit
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
History
Changed by the 2025 tax lawAdded in 1962 by the Public Law 87-834. Last changed July 4, 2025 by the One Big Beautiful Bill Act (2025).
Every change, newest first (4)
- July 4, 2025One Big Beautiful Bill Act (2025)
- December 22, 2017Tax Cuts and Jobs Act (2017)
- October 4, 1976Tax Reform Act of 1976
- October 16, 1962Public Law 87-834 · added this section
The law as written
Current through Public Law 119-102. Amendment notes omitted.
If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under subsections (a) and (d) of section 960 (determined without regard to the phrase “90 percent of” in subsection (d)(1) thereof) for such taxable year shall be treated for purposes of this title (other than sections 245 and 245A) as a dividend received by such domestic corporation from the foreign corporation.