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TITLE 26-.INTERNAL REVENUE CODE mains in effect, the credit under subsection (b)(3) shall be allowed to citizens or subjects of such foreign country only if such foreign coun- try, in imposing income, war profits, and excess profits taxes, allows to citizens of the United States residing in such foreign country such a similar credit. (d) Treatment of dividends from a DISC or former DISC For purposes of this subpart, dividends from a DISC or former DISC (as defined in section 992(a)) shall be treated as dividends from a for- eign corporation to the extent such dividends are treated under part I as income from sources without the United States. (e) Foreign taxes on mineral income (1) Reduction in amount allowed Notwithstanding subsection (b), the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or possession of the United States with respect to foreign mineral income from sources within such country or possession which would (but for this para- graph) be allowed under such subsection shall be reduced by the amount (if any) by which- (A) the amount of such taxes (or, if small- er, the amount of the tax which would be computed under this chapter with respect to such income determined without the de- duction allowed under section 613), exceeds (B) the amount of the tax computed under this chapter with respect to such income. (2) Foreign mineral income defined For purposes of paragraph (1), the term "foreign mineral income" means income de- rived from the extraction of minerals from mines, wells, or other natural deposits, the processing of such minerals into their prima- ry products, and the transportation, distribu- tion, or sale of such minerals or primary prod- ucts. Such term includes, but is not limited to- (A) dividends received from a foreign cor- poration in respect of which taxes are deemed paid by the taxpayer under section 902, to the extent such dividends are attrib- utable to foreign mineral income, and (B) that portion of the taxpayer's distrib- utive share of the Income of partnerships attributable to foreign mineral income. (f) Certain payments for oil or gas not considered as taxes Notwithstanding subsection (b) and sections 902 and 960, the amount of any income, or prof- its, and excess profits taxes paid or accrued during the taxable year to any foreign country in connection with the purchase and sale of oil or gas extracted in such country is not to be considered as tax for purposes of section 275(a) and this section if- (1) the taxpayer has no economic interest in the oil or gas to which section 611(a) applies, and (2) either such purchase or sale is at a price which differs from the fair market value for such oil or gas at the time of such purchase or sale. (g) Certain taxes paid with respect to distributions from possessions corporations (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, to the extent that such distribution is attributable to periods during which such corporation is a possessions corporation, shall not be treated as income, war profits, or excess profits taxes paid or accrued to a foreign country or pos- session of the United States, and no deduc- tion shall be allowed under this title with re- spect to any amount so paid or accrued. (2) Possessions corporation For purposes of paragraph (1), a corpora- tion shall be treated as a possessions corpora- tion for any period during which an election under section 936 applied to such corporation or 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. (h) Cross reference (I) For deductions of income, war profits, and excess profits taxes paid to a foreign country or a possession of the United States, see sections 164 and 275. (2) For right of each partner to make election under this section, see section 703tb). (3) For right of estate or trust to the credit for taxes imposed by foreign countries and possessions of the United States under this section, see section 642(a)(1). (4) For reduction of credit for failure of a United States person to furnish certain information with respect to a foreign corporation controlled by him, see section 6038. (Aug. 16, 1954, ch. 736, 68A Stat. 285; Sept. 14, 1960, Pub. L. 86-780, §3(a), (b), 74 Stat. 1013; Oct. 16, 1962, Pub. L. 87-834, §§ 9(d)(3). 12(b)(1), 76 Stat. 1001, 1031; Feb. 26, 1964, Pub. L. 88- 272, title II, § 207(b)(7), 78 Stat. 42; Apr. 8, 1966, Pub. L. 89-384, § 1(c)(2), 80 Stat. 102; Nov. 13, 1966, Pub. L. 89-809, title I, § 106(a)(4), (5), (b)(1), (2), 80 Stat. 1569; Dec. 30, 1969, Pub. L. 91-172, title III, § 301(b)(9), title V, § 506(a), 83 Stat. 585, 634; Dec. 10, 1971, Pub. L. 92-178, title V, § 502(b)(1), 85 Stat. 549; Sept. 2, 1974, Pub. L. 93-406, title II, §§ 2001(g)(2)(C), 2002(g)(3), 2005(c)(5), 88 Stat. 957, 968, 991; Mar. 29, 1975, Pub. L. 94-12, title VI, § 601(b), 89 Stat. 57; Oct. 4, 1976, Pub. L. 94-455, title X, §§ 1031(b)(1), 1051(d), title XIX, § 1901(b)(1)(H)(ii), (37)(A), 90 Stat. 1622, 1645, 1791, 1803.) REFERENCES IN TEXT The Tax Reform Act of 1976, referred to in subsec. (g)(2), Is Pub. L. 94-455, Oct. 4, 1976, 90 Stat. 1520, which was enacted Oct. 4, 1976. For complete classifi- cation of this Act to the Code, see Tables volume. AMENDMENTS 1976-Subsec. (a). Pub. L. 94-455, §§ 1031(b)(1), 1901(b)(37)(A), struck out "under section 1333 (relat- ing to war loss recoveries) or" following "imposed for the taxable year" and "applicable" following "subject to the". Subsec. (b). Pub. L. 94-455, § 1031(b)(1), struck out "applicable" following "Subject to the". Subsec. (d). Pub. L. 94-455, § 1051(d)(1), struck out provisions relating to corporations receiving a large percentage of their gross receipts from sources within a possession of the United States and a corporation or- § 901 Page 576