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TITLE 26-INTERNAL REVENUE CODE The preceding sentence shall not apply for purposes of determining the amount of any deduction allowable under section 611 [section 611 of this title] or the amount of foreign tax credit allowable under section 904 of such Code [section 904 of this title]." PART V-CONTINENTAL SHE-11 AREAS Sec. 638. Continental shelf areas. AMENDmNTS 1969-Pub. L. 91-172, title V, § 505(a), Dec. 30, 1969, 83 Stat. 634, added Part heading and section analysis. § 638. Continental shelf areas For purposes of applying the provisions of thLq chapter (including sections 861(a)(3) and 862(a)(3) in the case of the performance of per- sonal services) with respect to mines, oil and gas wells, and other natural deposits- (1) the term "United States" when used in a geographical sense includes the seabed and subsoil of those submarine areas which are adjacent to the territorial waters of the United States and over which the United States has exclusive rights, in accordance with international law, with respect to the ex- ploration and exploitation of natural re- sources; and (2) the terms "foreign country" and "pos- session of the United States" when used in a geographical sense include the seabed and subsoil of those submarine areas which are adjacent to the territorial waters of the for- eign country or such possession and over which the foreign country (or the United States in case of such possession) has exclu- sive rights, in accordance with international law, with respect to the exploration and ex- ploitation of natural resources, but this para- graph shall apply in the case of a foreign country only if it exercises, directly or indi- rectly, taxing Jurisdiction with respect to such exploration or exploitation. No foreign country shall, by reason of the ap- plication of this section, be treated as a country contiguous to the United States. (Added Pub. L. 91-172 title V, § 505(a), Dec. 30, 1969, 83 Stat. 634.) SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in section 1441 of this title. Subchapter J-Estates, Trusts, Beneficiaries, and Decedents Part I. Estates, trusts, and beneficiaries. II. Income in respect of decedents. SuBcHAPTER REFERRED TO IN OTHER SECTIONS This subchapter is referred to in sections 102, 511, 2055 of this title. PART I-ESTATES, TRUSTS, AND BENEFICIARIES Subpart A. General rules for taxation of estates and trusts. B. Trusts which distribute current income only. C. Estates and trusts which may accumulate income or which distribute corpus. D. Treatment of excess distributions by trusts. Subpart E. Grantors and others treated as substantial owners. F. Miscellaneous. PART REFERRJD TO IN OTHER SECTIONS This part is referred to in sections 543, 553 of this title. SUBPART A-GENERAL RULES FOR TAXATION OF ESTATES AND TRUSTS Sec. 641. Imposition of tax. 642. Special rules for credits and deductions. 643. Definitions applicable to subparts A, B, C, and D. 644. Special rule for gain on property transferred to trust at less than fair market value. AMENDmENTs 1976-Pub. L. 94-455, title VII, § 701(g)(2), Oct. 4, 1976, 90 Stat. 1580, added item 644. SUBPART REFEmuD TO IN OTHER SECTIONS This subpart is referred to in section 671 of this title. § 641. Imposition of tax (a) Application of tax The tax imposed by section l(d) shall apply to the taxable income of estates or of any kind of property held in trust, including- (1) income accumulated in trust for the benefit of unborn or unascertained persons or persons with contingent interests, and income accumulated or held for future distribution under the terms of the will or trust; (2) income which is to be distributed cur- rently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct; (3) income received by estates of deceased persons during the period of administration or settlement of the estate; and (4) income which, in the discretion of the fi- duciary, may be either distributed to the beneficiaries or accumulated. (b) Computation and payment The taxable income of an estate or trust shall be computed in the same manner as in the case of an individual, except as otherwise provided in this part. The tax shall be computed on such taxable income and shall be paid by the fidu- ciary. (c) Exclusion of includible gain from taxable income (1) General rule For purposes of this part, the taxable income of a trust does not include the amount of any includible gain as defined in section 644(b) reduced by any deductions properly allocable thereto. (2) Cross reference For the taxation of any includible gain, see section 644. (Aug. 16, 1954, ch. 736, 68A Stat. 215; Dec. 30, 1969, Pub. L. 91-172, title VIII, § 803(d)(3), 83 Stat. 684; Oct. 4, 1976, Pub. L. 94-455, title VII, § 701(e)(2), 90 Stat. 1579.) AMENDMENTS 1976-Subsec. (c). Pub. L. 94455 added subsec. (c). .1969-Subsec. (a). Pub. L. 91-172 substituted "The tax imposed by section l(d)", for "The Taxes imposed by this chapter on individuals". 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