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TITLE 26-INTERNAL REVENUE CODE same extent as they apply in respect of elec- tions under section 871(d). (e) Interest on United States obligations received by banks organized in possessions In the case of a corporation created or orga- nized in, or under the law of, a possession of the United States which is carrying on the banking business in a possession of the United States, interest on obligations of the United States shall- (1) for purposes of this subpart, be treated as income which is effectively connected with the conduct of a trade or business within the United States, and (2) shall be taxable as provided In subsec- tion (a)(1) whether or not such corporation is engaged in trade or business within the United States during the taxable year. (f) Returns of tax by agent If any foreign corporation has no office or place of business in the United States but has an agent in the United States, the return re- quired under section 6012 shall be made by the agent. (Aug. 16, 1954, ch. 736, 68A Stat. 282; Nov. 13, 1966, Pub. L. 89-809, title I, § 104(b)(1), 80 Stat. 1555; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834.) AMENDMENTS 1976-Subsecs. (c)(1)(A), (2), (d). Pub. L. 94-455 struck out "or his delegate" following "Secretary". 1966-Pub. L. 89-809 substantially revised the income tax treatment of foreign corporations, intro- duced the concept of taxable income effectively con- nected with the conduct of a trade or business within the United States into provisions dealing with the Im- position of tax, substituted a concept of gross income that included gross income derived from sources within the United States not effectively connected with the conduct of a trade or business within the United States and gross income effectively connected with the conduct of a trade or business within the United States for a concept of gross income that in- cluded only gross income from sources within the United States, and inserted provisions for an election to treat real property income as income connected with United States business, treatment of interest on United States obligations received by banks organized in possessions, and the returns of tax by agents, and added cross reference to section 906(b)(1). EFFECTIVE DATE OF 1966 AMENDMENT Amendment by Pub. L. 89-809 applicable with re- spect to taxable years beginning after Dec. 31, 1966, see section 104(n) of Pub. L. 89-809, set out as an Ef- fective Date of 1966 Amendment note under section 11 of this title. SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 11, 819A, 864, 906, 1442 of this title. § 883. Exclusions from gross income (a) Income of foreign corporations from ships and aircraft The following items shall not be included in gross income of a foreign corporation, and shall be exempt from taxation under this subtitle: (1) Ships under foreign flag Earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States. (2) Aircraft of foreign registry Earnings derived from the operation of air- craft registered under the laws of a foreign country which grants an equivalent exemp- tion to citizens of the United States and to corporations organized in the United States. (3) Railroad rolling stock of foreign corporations Earnings derived from payments by a common carrier for the use on a temporary basis (not expected to exceed a total of 90 days in any taxable year) of railroad rolling stock owned by a corporation of a foreign country which grants an equivalent exemp- tion to corporations organized in the United States, (b) Earnings derived from communications satellite System The earnings derived from the ownership or operation of a communications satellite system by a foreign entity designated by a foreign gov- eminent to participate in such ownership or op- eration shall be exempt from taxation under this subtitle, if the United States, through its designated entity, participates in such system pursuant to the Communications Satellite Act of 1962 (47 U.S.C. 701 and following). (Aug. 16, 1954, ch. 736, 68A Stat. 283: Oct. 22, 1968, Pub. L. 90-622, § l(a), 82 Stat. 1311; Dec. 23, 1975, Pub. L. 94-164, § 6(a), 89 Stat. 975.) REFERENCES IN TEXT The Communications Satellite Act of 1962, referred to in subsec. (b), is Pub. L. 87-624, Aug. 31, 1962, 76 Stat. 419, as amended, which is classified generally to chapter 6 (§ 701 et seq.) of Title 47, Telegraphs, Tele- phones, and Radiotelegraphs. For complete classifica- tion of this Act to the Code, see Short Title note set out under section 701 of Title 47 and Tables volume. AMENDMENTS 1975-Subsec. (a). Pub. L. 94-164 added par. (3). 1968-Subsec. (a). Pub. L. 90-622 denominated exist- ing provisions as subsec. (a) and added the subsec. catchline "Income of foreign corporations from ships and aircraft". Subsec. (b). Pub. L. 90-622 added subsec. (b). EFFECTIVE DATE OF 1975 AMENDMENT Section 6(b) of Pub. L. 94-164 provided that: "The amendment made by this section [amending this sec- tion] shall apply to payments made after November 18, 1974." EFFECTIVE DATE OF 1968 AMENDMENr Section l(b) of Pub. L. 90-622 provided that: "The amendment made by subsection (a) (adding subsec. (b) to this section] shall apply with respect to taxable years beginning after December 31, 1966." § 884. Cross references (1) For special provisions relating to foreign corpora- tions carrying on an insurance business within the United States, see section 842. (2) For rules applicable In determining whether any foreign corporation is engaged In trade or business within the United States, see section 864(b). (3) For adjustment of tax in case of corporations of certain foreign countries, see section 896. (4) For allowance of credit against the tax in case of a foreign corporation having income effectively connected Page 571 § 884