26 U.S.C. § 906
§ 906. Nonresident alien individuals and foreign corporations
No plain-English explainer yet. Below is the official text. Explainers are being added section by section.
History
Added in 1966 by the Public Law 89-809. Last changed December 22, 2017 by the Tax Cuts and Jobs Act (2017).
Every change, newest first (6)
- December 22, 2017Tax Cuts and Jobs Act (2017)
- December 29, 2007Public Law 110-172
- November 10, 1988Technical and Miscellaneous Revenue Act of 1988
- October 22, 1986Tax Reform Act of 1986
- July 18, 1984Deficit Reduction Act of 1984
- November 13, 1966Public Law 89-809 · added this section
The law as written
Current through Public Law 119-102. Amendment notes omitted.
A nonresident alien individual or a foreign corporation engaged in trade or business within the United States during the taxable year shall be allowed a credit under section 901 for the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or possession of the United States with respect to income effectively connected with the conduct of a trade or business within the United States.
For purposes of subsection (a) and for purposes of determining the deductions allowable under sections 873(a) and 882(c), in determining the amount of any tax paid or accrued to any foreign country or possession there shall not be taken into account any amount of tax to the extent the tax so paid or accrued is imposed with respect to income from sources within the United States which would not be taxed by such foreign country or possession but for the fact that—
in the case of a nonresident alien individual, such individual is a citizen or resident of such foreign country or possession, or
in the case of a foreign corporation, such corporation was created or organized under the law of such foreign country or possession or is domiciled for tax purposes in such country or possession.
For purposes of subsection (a), in applying section 904 the taxpayer’s taxable income shall be treated as consisting only of the taxable income effectively connected with the taxpayer’s conduct of a trade or business within the United States.
The credit allowed pursuant to subsection (a) shall not be allowed against any tax imposed by section 871(a) (relating to income of nonresident alien individual not connected with United States business) or 881 (relating to income of foreign corporations not connected with United States business).
, (5) Repealed. Pub. L. 115–97, title I, § 14301(c)(23), Dec. 22, 2017, 131 Stat. 2223.]
No credit shall be allowed under this section against the tax imposed by section 884.