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REGISTE
VOLUME 17

/ J 9 3 it C ,
V /T E O

NUMBER 230

Washington, Tuesday, November 25, 7952

TTLE 26- INTERNAL REVENUE
Chapter I Bureau of Internal Reve nue, Department of the Treasury Subchapter A-Income and Excess-Profits Taxes Regs. I l l ; T . D. 5947
P art 29I n c o m e T a x ; T a x a b l e Y ears B e g in n in g A f t e r D e c e m b e r 31, 1941
CREDIT FOR TAXES OF FOREIGN CORPORATIONS

On September 27,1952, there was pub lished in the F ederal R e g is t e r 17 F . R .
8634 a notice of proposed rule making to conform Regulations 111 26 CFR
Part 29 to section 332 of the Revenue Act of 1951, relating to credit for taxes of foreign corporations, approved Oc tober 20,1951. No objection to the rules proposed having been received, the amendments set forth below are hereby adopted.
P aragraph 1. There is inserted imme diately preceding 29.131 the following:
Sec. 332. C redit for taxes of foreign cor
REVENUE ACT OF 1951, APPROVED
OCTOBER 20, 1951.
porations
a F oreign subsid iary o f a d o m estic c o r
poration. E ffective w ith resp ect to d iv i dends received b y a d om estic c o rp o ra tio n from a foreig n co rp o ra tio n d u rin g taxable years beginning after D ecem ber 31, 1950, th e first sentence o f se ctio n 131 f 1 is h ere by amended b y strikin g o u t a m a jo rity and inserting in lieu th e re o f at least 10 per centum .
b F oreign subsidiary o f a fo reig n c o rp o
ration. Effective w ith respect to d ividends received by a fo re ig n co rp o ra tio n fro m a n
other foreign co rp o ra tio n in taxable years beginning after D ecem ber 31, 1950, section 131 f 2 is h ereby aniended b y strik in g out all the v otin g stock ex cep t qu a lify in g shares an d in sertin g in lie u th e r e o f 50
per centum or m ore o f th e v o tin g sto ck .
c Clerical a m en d m en t. S o m u ch o f sec tion 131 f 1 as precedes th e first sen
tence thereof is h ereby am ended to read as follows:
f Taxes o f fo r e ig n corp ora tion s 1
Treatment o f ta x es paid b y fo r e ig n corp ora
tion.
P ar. 2. Section 29.131-3, as amended by Treasury Decision 5893, approved April 4, 1952, is further amended by re vising the first sentence, which com mences with the words For credit where taxes,, of paragraph d thereof to read as follows: For credit available to a do
mestic corporation with respect to taxes CONTENTS
paid by a foreign corporation, see Agriculture Department pa&e 29.131-7.
Par. 3. Section 29.131-7, as amended See Animal Industry Bureau.
by Treasury Decision 5452, approved Air Force Department April 19,1945, is further amended as fol Rules and regulations:
lows:
Procurement procedures; in A By revising so much thereof as spection and acceptance___ 10686
precedes the words of the voting stock Animal Industry Bureau of a foreign corporation , which appear Proposed rule making:
in the first sentence of paragraph a Recognition of breeds and books thereof, to read as follows:
of record of purebred ani 29.131-7 Taxes of foreign corpora mals__________________
10707
tion a Domestic corporation owning stock of a foreign corporation. In the Army Department case of a domestic corporation which Rules and regulations:
Reserve Officers T ra in in g owns a majority or, effective with re Corps; miscellaneous amend spect to dividends received during a tax ments__________
10685
able year beginning after December 31, 1950, at least 10 percent .
Civil Aeronautics Board B By striking out of the expression Notices:
Frontier Airlines, Inc. et al.;
paid or accrued by such controlled for Route 93 renewal case; notice eign corporation to any foreign coun of oral argument:______
10710
try, which appears in the first sentence of paragraph a thereof, the word con Proposed rule making:
Pilot and medical certificate re trolled so that such expression will read quirements for copilots_____ 10709
as follows: paid or accrued by such foreign corporation to any foreign coun Defense Department try.
See Air Force Department; Army 4 0 By revising the second and third Department.
sentences of -paragraph a thereof, Economic Stabilization Agency which commence, respectively, with the See Price Stabilization, Office of;
words See, however, the limitations Rent Stabilization, Office of;
and If dividends are received , to read Wage Stabilization Board.
as follows: If dividends are received Federal Power Commission from more than one such foreign cor poration, the limitation is to be com Notices:
United Gas Pipe Line Co.; order puted separately for the dividends re reopening proceedings and fix ceived from each. For other limitations ing date of hearing________ 10710
upon the amount of credit available un Internal Revenue Bureau der section 131, see 29.131-8.
Reorganization; abolition and D By striking out of the last sentence establishment of certain offices of paragraph a> thereof a controlled see Treasury Department.
and inserting in lieu thereof such a , so Proposed rule making:
that such sentence will read as follows:
Excess profits taxes; taxable Taxes paid or accrued by such a for years ending after June 30, eign corporation are deemed to have 1950; computation of income been paid by the domestic corporation on accrual method_________ 10706
Income tax; taxable years be for purposes of credit only.
ginning after December 31, E By revising the headnote of para 1941; foreign tax credit_____ 10705
graph b and paragraph b 1 there Rules and regulations:
of to read as follows:
Income tax; taxable years be b Foreign corporation owning stock ginning after December 31, of another foreign corporation. 1 If 1941; credit for taxes of for eign corporations_________ - 10683
C o n tin u ed o n n ex t page 10683