Internal Revenue Code · 26 U.S.C.
§ 27. Taxes of foreign countries and possessions of the United States
Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).
Cite as 26 U.S.C. § 27
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Enacted
- October 4, 1976 by Pub. L. 94–455
- Last amended
- March 23, 2018 by Pub. L. 115–141
- Amendments
- 2 dated changes in the source credit
- Length
- 96 words · about 1 min to read
- Cross-references
- cites 1; cited by 8 Code sections and 10 other regulations
The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901 11 So in original. Probably should be followed by a period.
(Aug. 16, 1954, ch. 736, 68A Stat. 13, § 33; Pub. L. 94–455, title X, § 1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered § 27, Pub. L. 98–369, div. A, title IV, § 471(c), July 18, 1984, 98 Stat. 826; Pub. L. 115–141, div. U, title IV, § 401(d)(1)(A), Mar. 23, 2018, 132 Stat. 1206.)
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 1 other section
Cited by 8 Code sections
- § 26(a)(1) Limitation based on tax liability; definition of tax liability
- § 30C(d)(2)(A) Alternative fuel vehicle refueling property credit
- § 55(c)(1) Alternative minimum tax imposed
- § 59(a)(1) Other definitions and special rules
- § 108(b)(2)(G) Income from discharge of indebtedness
- § 469(c)(3)(B) Passive activity losses and credits limited
- § 691(b) Recipients of income in respect of decedents
- § 1351(i)(1) Treatment of recoveries of foreign expropriation losses
Cited in 10 regulations not issued under it
- § 1.28-1 Credit for clinical testing expenses for certain drugs for rare diseases or conditions.
- § 1.30D-1 Credit for new clean vehicles.
- § 1.337(d)-2 Loss limitation rules.
- § 1.469-3T Passive activity credit (temporary).
- § 1.761-2 Exclusion of certain unincorporated organizations from the application of all or part of subchapter K of chapter 1 of the Internal Revenue Code.
- § 1.932-1 Coordination of United States and Virgin Islands income taxes.
- § 1.1411-1 General rules.
- § 1.1502-2 Computation of tax liability.
- § 1.1502-43 Consolidated accumulated earnings tax.
- § 301.6722-1 Failure to furnish correct payee statements.
Amendment history
From the source credit and the official notes, newest first.
- Amended by Pub. L. 115–141
- Amended by Pub. L. 98–369
- Enacted by Pub. L. 94–455
Where it sits in the Code
- Subtitle A Income Taxes
- Chapter 1 NORMAL TAXES AND SURTAXES
- Subchapter A Determination of Tax Liability
- Part IV CREDITS AGAINST TAX
- Subpart B Other Credits
Nearby sections
- § 27 Taxes of foreign countries and possessions of the United States
- § 28 Renumbered
- § 29 Renumbered
- § 30 Repealed
- § 30A Repealed
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Amendments
2018—Pub. L. 115–141 amended section generally. Prior to amendment, section consisted of subsecs. (a) and (b) relating to the foreign tax credit under section 901 and the tax credit under section 936, respectively.
1984—Pub. L. 98–369, § 471(c), renumbered section 33 of this title as this section.
1976—Pub. L. 94–455 designated existing provisions as subsec. (a) and added subsec. (b).
Statutory Notes and Related Subsidiaries
Effective Date of 1976 Amendment
Pub. L. 94–455, title X, § 1051(i), Oct. 4, 1976, 90 Stat. 1647, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
“(1) Except as provided by paragraph (2), the amendments made by this section [enacting section 936 of this title and amending sections 33 [now 27], 48, 116, 243, 246, 861, 901, 904, 931, 1504, and 6091 of this title] shall apply to taxable years beginning after December 31, 1975, except that ‘qualified possession source investment income’ as defined in [former] section 936(d)(2) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] shall include income from any source outside the United States if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or his delegate that the income from such sources was earned before October 1, 1976.“(2) The amendment made by subsection (d)(2) [amending section 901 of this title] shall not apply to any tax imposed by a possession of the United States with respect to the complete liquidation occurring before January 1, 1979, of a corporation to the extent that such tax is attributable to earnings and profits accumulated by such corporation during periods ending before January 1, 1976.”
Savings Provision
For provisions that nothing in amendment by Pub. L. 115–141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. 23, 2018, for purposes of determining liability for tax for periods ending after Mar. 23, 2018, see section 401(e) of Pub. L. 115–141, set out as a note under section 23 of this title.