Certain taxes paid with respect to distributions from possessions corporations
(1) In general
(1)In general#
For purposes of this chapter, any tax of a foreign country or possession of the United States which is paid or accrued with respect to any distribution from a corporation—
(A) to the extent that such distribution is attributable to periods during which such corporation is a possessions corporation, and
(B) (i) if a dividends received deduction is allowable with respect to such distribution under part VIII of subchapter B, or (ii) to the extent that such distribution is received in connection with a liquidation or other transaction with respect to which gain or loss is not recognized,
shall not be treated as income, war profits, or excess profits taxes paid or accrued to a foreign country or possession of the United States, and no deduction shall be allowed under this title with respect to any amount so paid or accrued.
(1)(A)#
to the extent that such distribution is attributable to periods during which such corporation is a possessions corporation, and
(1)(B)#
(i) if a dividends received deduction is allowable with respect to such distribution under part VIII of subchapter B, or
(ii) to the extent that such distribution is received in connection with a liquidation or other transaction with respect to which gain or loss is not recognized,
(2)Possessions corporation#
For purposes of paragraph (1), a corporation shall be treated as a possessions corporation for any period during which an election under section 936 (as in effect on the day before the date of the enactment of the Tax Technical Corrections Act of 2018) applied to such corporation, during which section 931 (as in effect on the day before the date of the enactment of the Tax Reform Act of 1976) applied to such corporation, or during which section 957(c) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986) applied to such corporation.