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TITLE 26-INTERNAL REVENUE CODE (d) Certain dividends from foreign corporations For purposes of subsection (a) and for pur- poses of section 245, any dividend from a for- eign corporation from earnings and profits ac- cumulated by a domestic corporation during a period with respect to which such domestic cor- poration was subject to taxation under this chapter (or corresponding provisions of prior law) shall be treated as a dividend from a do- mestic corporation which is subject to taxation under this chapter. (Aug. 16, 1954, ch. 736, 68A Stat. 73; Sept. 2, 1958, Pub. L. 85-866, title I, § 57(b), 72 Stat. 1645; Sept. 14, 1960, Pub. L. 86-779, §§3(a), 10(g), 74 Stat. 998, 1009; Feb. 26, 1964, Pub. L. 88-272, title II, § 214(a), 78 Stat. 52; June 28, 1968, Pub. L. 90-364, title I, § 103(e)(2), 82 Stat. 264; Dec. 30, 1969, Pub. L. 91-172, title V, § 504(c)(1), 83 Stat, 633; Mar. 29, 1975, Pub. L. 94-12, title III, § 304(b), 89 Stat. 45; Oct. 4, 1976, Pub. L. 94-455, title X, §§ 1031(b)(2), 1051(f)(1), (2), title XIX, §§ 1901(a)(34), (b)(1)(J)(ii), (21)(A)(i), 1906(b)(3)(C)(ii), (13)(A), 90 Stat. 1622, 1646, 1769, 1791, 1797, 1833, 1834.) REFERENCES IN TEXT The Small Business Investment Act of 1958, referred to in subsec. (a)(2), is Pub. L. 85-699, Aug. 21, 1958, 72 Stat. 689, as amended, which is classified principally to chapter 14B (§ 661 et seq.) of Title 15, Commerce and Trade. For complete classification of this Act to the Code, see Short Title note set out under section 661 of Title 15 and Tables volume. AMENDMENTS 1976-Subsec. (a)(2). Pub. L. 94-455, § 1901(a)(34)(A), added "(15 U.S.C. 661 and following)" after "Small Business Investment Act of 1958". Subsec. (b)(1). Pub. L. 94-455, § 1051(f)(1), added "either" at the end of subpar. (A), substituted a comma for a period and added "or" at the end of subpar. (B), and added subpar. (C). Subsecs. (b)(2), (3), (4), Pub. L. 94-455, title XIX, § 1906(b)(13)(A), struck out "or his delegate" following "Secretary". Subsec. (b)(2)(A). Pub. L. 94-455, § 1901(a)(34)(B), struck out "(except that in the case of a taxable year of a member beginning in 1963 and ending in 1964, if the election is effective for the taxable year of the common parent corporation which includes the last day of such taxable year of such member, such elec- tion shall be effective for such taxable year of such member, if such member consents to such election with respect to such taxable year)" following "with re- spect to which the election is made". Subsec. (b)(3)(B). Pub. L. 94-455, § 1031(b)(2), substi- tuted "election under section 901(a) (relating to allowance of foreign tax credit)" for "elections under section 001(a) (relating to allowance of foreign tax credit) and section 904(b)(1) (relating to election of overall limitation)". Subsec. (b)(3)(C). Pub. L. 94-455, §§ 1901(b)(1)(J)(ii), (21)(A)(i). 1906(b)(3)(C)(ii), struck out cl. (ii) which set a $100,000 limitation for exploration expenditures under section 615 (a) and (b), redesignated former cls. (iii), (iv), and (v) as cls. (ii), (iII), and (iv), respectively, and substituted "certain exploration expenditures under section 617(h)(1)" for "exploration expenditures under sections 615(c)(1) and 617(h)(1)" in cl. (ii) ab so redesignated, "804(a)(Gi" for "804(a)(4)" in cl. (iii) as so redesignated, and "section 6154(c)(2) and section 6655(e)(2)" for "sections 6154(c)(2) and (3) and sec- tions 6655(e)(2) and (3)" in cl. (iv) as so redesignated. Subsee. (b)(5). Pub. L. 94-455, § 1051(f)(2), added ", 1504(b)(4)," after "sections 1504(b)(2)". 1975-Subsec. (b)(3)(C)(i). Pub. L. 94-12 substituted "$150,000" for 1$100,000". 1969-Subsec. (b)(3)(C)(iii). Pub. L. 91-172 substitut- ed "sections 615(c)(1) and 617(h)(1)" for "section 615(c)(1)". 1968-Subsec. (b)(3)(C)(v). Pub. L. 90-364 substitut- ed "surtax exemption, and one amount under section 6154(c)(2) and (3) and sections 6655(e)(2) and (3), for purposes of estimated tax payment requirements under section 6154" for "$100,000 exemption for pur- poses of estimated tax filing requirements under sec- tion 6016". 1964-Subsec. (a). Pub. L. 88-272 substituted provi- sions permitting a deduction for 85 percent of divi- dends received except that it shall be 100 percent when received by a small business investment compa- ny operating under the Small Business Investment Act of 1958, and 100 percent in case of qualifying divi- dends, for provisions permitting an 85 percent deduc- tion for corporations other than one operating under the Small Business Investment Act of 1958, and for other than dividends described in section 244(1) of this title. Subsec. (b). Pub. L. 88-272 added subsec. (b) and omitted a prior subsec. (b) which allowed a 100 per- cent deduction of dividends received by a small busi- ness investment company operating under the Small Business Investment Act of 1958, other than dividends described in section 244(1) of this title. Subsec. (c). Pub. L. 88-272 substitiited "subsection (a)" for "subsections (a) and (b)", and added par. (4). Subsec. (d). Pub. L. 88-272 substituted "subsection (a)" for "subsections (a) and (b)". 1960-Subsec. (c)(3). Pub. L. 86-779, § 10(g), added par. (3). Subsec. (d). Pub. L. 86-779, § 3(a), added subsec. (d). 1958-Subsec. (a). Pub. L. 85-866, § 57(b)(1), inserted "(other than a small business investment company op- erating under the Small Business Investment Act of 1958)". Subsec. (b). Pub. L. 85-866, § 57(b)(2), added subsec, (b) and redesignated former subsec. (b) as (c). Subsec. (c). Pub. L. 85-866, § 57(b)(2), (3), redesignat- ed former subsec. (b) as (c) and substituted "subsec- tions (a) and (b)" for "subsection (a)". EFFECTIVE DATE OF 1976 AMENDMENT Amendment of subsecs. (a) and (b) by sections 1901(a)(34), (b)(1), (21), of Pub. L. 94-455 effective for taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under section 2 of this title, For effective date of amendment of subsec. (b)(1), (5), by section 1051(f)(1), (2) of Pub. L. 94-455, see sec- tion 1051(i) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under section 33 of this title. For effective date of amendment of subsec. (b)(3) by section 1031(b)(2) of Pub. L. 94-455, see section 1031(c) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note set out under section 904 of this title. For effective date of amendment of subsec. (b)(3)(C) by section 1906(b)(3)(C)(ii) of Pub. L. 94-455, see sec- tion 1906(d) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under section 6013 of this title. EFFECTIVE DATE OF 1975 AMENDMENT Amendment by section 304 of Pub. L. 94-12 applica- ble to taxable years beginning after Dec. 31, 1974, see section 305(c) of Pub. L. 94-12, set out as an Effective Date of 1975 Amendment note under section 535 of this title. EFFECTIVE DATE OF 1969 AMENDMENT Section 504(d) of Pub. L. 91-172 provided that: "(1) In general.-The amendments made by this sec- tion [amending sections 243, 381, 615, 617, 703 and 1016 of this title] shall apply with respect to explora- tion expenditures paid or incurred after December 31, 1969. § 243 Page 204