Internal Revenue Code · 26 U.S.C.
§ 902. Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221
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. § 902
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- Repealed
- Cross-references
- cites 0; cited by 4 Code sections and 66 other regulations
- Regulations
- 5 issued under this section
Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221
Regulations under this section
Treasury regulations (26 CFR) issued under § 902
- § 1.902-0 Outline of regulations provisions for section 902.
- § 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation.
- § 1.902-2 Treatment of deficits in post-1986 undistributed earnings and pre-1987 accumulated profits of a first- or lower-tier corporation for purposes of computing an amount of foreign taxes deemed paid under § 1.902-1.
- § 1.902-3 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before January 1, 1987.
- § 1.902-4 Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation.
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
Cited by 4 Code sections
- § 904(d)(1) Limitation on credit
- § 1248(d)(3) Gain from certain sales or exchanges of stock in certain foreign corporations
- § 1293(f)(3) Current taxation of income from qualified electing funds
- § 6038(a)(1)(B) Information reporting with respect to certain foreign corporations and partnerships
Cited in 66 regulations not issued under it
- § 1.338-9 International aspects of section 338.
- § 1.367(a)-6T Transfer of foreign branch with previously deducted losses (temporary).
- § 1.367(b)-2 Definitions and special rules.
- § 1.367(b)-4 Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions.
- § 1.367(b)-7 Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.
- § 1.367(b)-10 Acquisition of parent stock or securities for property in triangular reorganizations.
- § 1.535-2 Adjustments to taxable income.
- § 1.545-2 Adjustments to taxable income.
- § 1.672(f)-4 Recharacterization of purported gifts.
- § 1.701-2 Anti-abuse rule.
- § 1.704-1 Partner's distributive share.
- § 1.853-1 Foreign tax credit allowed to shareholders.
- § 1.861-3 Dividends and income inclusions under sections 951, 951A, and 1293 and associated section 78 dividends.
- § 1.861-12T Characterization rules and adjustments for certain assets (temporary).
- § 1.901-2A Dual capacity taxpayers.
- § 1.901-3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit.
- § 1.901(m)-1 Definitions.
- § 1.901(m)-3 Disqualified tax amount and aggregate basis difference carryover.
- § 1.904-2 Carryback and carryover of unused foreign tax.
- § 1.904-7 Transition rules.
- § 1.904(f)-0 Outline of regulation provisions.
- § 1.904(f)-12 Transition rules.
- § 1.905-5 Foreign tax redeterminations of foreign corporations that relate to taxable years of the foreign corporation beginning before January 1, 2018.
- § 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
Show 42 more
- § 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
- § 1.907(c)-3 FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).
- § 1.907(f)-1 Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).
- § 1.909-0 Outline of regulation provisions for section 909.
- § 1.909-1 Definitions and special rules.
- § 1.909-2 Splitter arrangements.
- § 1.909-3 Rules regarding related income and split taxes.
- § 1.909-5 2011 and 2012 splitter arrangements.
- § 1.909-6 Pre-2011 foreign tax credit splitting events.
- § 1.952-1 Subpart F income defined.
- § 1.954-6 Foreign base company shipping income.
- § 1.955-0 Effective dates.
- § 1.959-3 Allocation of distributions to earnings and profits of foreign corporations.
- § 1.960-3 Foreign income taxes deemed paid under section 960(b).
- § 1.960-4 Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
- § 1.962-3 Treatment of actual distributions.
- § 1.963-2 Determination of the amount of the minimum distribution.
- § 1.963-3 Distributions counting toward a minimum distribution.
- § 1.963-6 Deficiency distribution.
- § 1.964-1 Determination of the earnings and profits of a foreign corporation.
- § 1.965-0 Outline of section 965 regulations.
- § 1.965-2 Adjustments to earnings and profits and basis.
- § 1.965-4 Disregard of certain transactions.
- § 1.965-6 Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
- § 1.985-0 Outline of regulation.
- § 1.985-1 Functional currency.
- § 1.985-2 Election to use the United States dollar as the functional currency of a QBU.
- § 1.985-6 Transition rules for a QBU that uses the dollar approximate separate transactions method for its first taxable year beginning in 1987.
- § 1.985-7 Adjustments required in connection with a change to DASTM.
- § 1.985-8 Special rules applicable to the European Monetary Union (conversion to euro).
- § 1.987-3T Determination of section 987 taxable income or loss of an owner of a section 987 QBU (temporary).
- § 1.1248-1 Treatment of gain from certain sales or exchanges of stock in certain foreign corporations.
- § 1.1248-2 Earnings and profits attributable to a block of stock in simple cases.
- § 1.1248-3 Earnings and profits attributable to stock in complex cases.
- § 1.1291-9 Deemed dividend election.
- § 1.1297-3 Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a section 1297(e) PFIC.
- § 1.1298-3 Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC.
- § 1.1503(d)-7 Examples.
- § 1.6038-1 Information returns required of domestic corporations with respect to annual accounting periods of certain foreign corporations beginning before January 1, 1963.
- § 1.6038-2 Information returns required of United States persons with respect to annual accounting periods of certain foreign corporations.
- § 1.6038-3 Information returns required of certain United States persons with respect to controlled foreign partnerships (CFPs).
- § 1.6045-2 Furnishing statement required with respect to certain substitute payments.
Where it sits in the Code
- Subtitle A Income Taxes
- Chapter 1 NORMAL TAXES AND SURTAXES
- Subchapter N Tax Based on Income From Sources Within or Without the United States
- Part III INCOME FROM SOURCES WITHOUT THE UNITED STATES
- Subpart A Foreign Tax Credit
Nearby sections
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Section, act Aug. 16, 1954, ch. 736, 68A Stat. 286; Pub. L. 86–780, § 6(b)(2), Sept. 14, 1960, 74 Stat. 1016; Pub. L. 87–834, § 9(a), Oct. 16, 1962, 76 Stat. 999; Pub. L. 91–684, §§ 1, 2, Jan. 12, 1971, 84 Stat. 2068, 2069; Pub. L. 94–12, title VI, § 602(c)(6), Mar. 29, 1975, 89 Stat. 59; Pub. L. 94–455, title X, § 1033(a), Oct. 4, 1976, 90 Stat. 1626; Pub. L. 99–514, title XII, § 1202(a), Oct. 22, 1986, 100 Stat. 2528; Pub. L. 100–647, title I, § 1012(b)(1), (2), Nov. 10, 1988, 102 Stat. 3496; Pub. L. 105–34, title XI, §§ 1113(a), 1163(a), Aug. 5, 1997, 111 Stat. 970, 987; Pub. L. 108–357, title IV, § 405(a), Oct. 22, 2004, 118 Stat. 1498, related to deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation.
Statutory Notes and Related Subsidiaries
Effective Date of Repeal
Repeal applicable to taxable years of foreign corporations beginning after Dec. 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 14301(d) of Pub. L. 115–97, set out as an Effective Date of 2017 Amendment note under section 78 of this title.