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TITLE 26-INTERNAL REVENUE CODE ganized under the China Trade Act. 1922 (15 U.S.C. chapter 4). Subsec. (g). Pub. L. 94-455, § 1051(d)(2), added subsec. (g), Former subsec. (g) redesignated subsec. (h). Subsec. (h). Pub, L. 94-455, §§ 1051(d)(2), 1901(b)(1)(H)(ii), redesignated former subsec. (g) as (h) and, as redesignated, substituted "section 642(a)(1)" for "section 642(a)(2)" in par. (3). 1975-Subsee. (M). Pub. L. 94-12 added subsec. i). Former subsec, f) redesignated (g), Subsec. (g). Pub. L. 94-12 redesignated former subsec. (f) as (g). 1974-Subsec. (a). Pub. L. 93-460 inserted references to the tax imposed for the taxable year under section 72(m)(5)(B) (relating to 10 percent tax on premature distributions to owner-employees), the tax imposed for the taxable year by section 408(f) (relating to addi- tional tax on income from certain retirement ac- counts), and the tax imposed by section 402(e) (relat- ing to tax on lump sum distributions). 1971-Subsec. (d). Pub. L. 92-178 added provision for treatment of dividends from a DISC or former DISC as dividends from a foreign corporation to the extent such dividends are treated under part I as income from sources without the United States. 1969-Subsec. (a). Pub, L. 91-172, § 301(b)(9), insert- ed in last sentence "against the tax imposed by section 56 (relating to minimum tax for tax preferences)," after "not be allowed". Subsec. (e). Pub. L. 91-172, §506(a), added subsec. (e). Former subsec. (e) redesignated (f). 1966-Subsec. (a). Pub. L. 89-384 added the addition- al tax imposed under section 1351 (relating to recover- ies of foreign expropriation losses) to the list of taxes against which the foreign tax credit may not be al- lowed. Subsec. (b)(3). Pub. L. 89-809, § 106(b)(1), struck out provisions which made the allowance of the credit de- pendent upon whether the foreign country of which the alien resident was a citizen or subject, in imposing such taxes, allowed a similar credit to citizens of the United States residing in such country. Subsec. (b)(4). Pub. L. 89-809, § 106(a)(4). added subsec. (a)(4). Former subsec. (a)(4) redesignated as (a)(5). Subsec. (b)(5). Pub. L. 89-809, § 106(a)(4), (5), rede- signated former subsec. (b)(4) as (b)(5) and, in subsec. (b)(5) as so redesignated, inserted reference to para- graph (4). Subsec. (c), Pub. L. 89-809, § 106(b)(2), added subsec. (c). Former subsec. (c) redesignated as (d). Subsecs. (d), e). Pub. L. 89-809, § 106(b)(2), redesig- nated former subsecs. (c) and (d) as (d) and (e), respec- tively. 1964-Subsec. (d)(1). Pub. L. 88-272 inserted the ref- erence to section 275. 1962-Subsec. (a). Pub. L. 87-834, § 12(b)(1), substi- tuted "sections 902 and 960" for "section 902". Subsec. (d)(4). Pub. L. 87-834, § 9(d)(3), added subsec. (d)(4). 1960--Subsec. (a). Pub. L. 86-780, § 3(a), (b), inserted "applicable" preceding "limitation" and substituted "Such choice for any taxable year may be made or changed at any time before the expiration of the period prescribed for making a claim for credit or refund of the tax Imposed by this chapter for such taxable year" for "Such choice may be made or changed at any time prior to the expiration of the period prescribed for making a claim for credit or refund of the tax against which the credit is allowa- ble." Subsec. (b). Pub. L. 86-780, § 3(b), inserted "applica- ble" preceding "limitation". EFFErIVE DATE OF 1976 AMENDMENT Amendment of subsecs. (a) and (b) by section 1031(b)(1) of Pub. L. 94-455 applicable to taxable years beginning after Dec. 31, 1975, with certain exceptions, see section 1031(c) of Pub. L. 94-455, set out as an Ef- fective Date of 1976 Amendment note under section 904 of this title. Amendment of subsec. (d) by sectiou 1051(d)(1) of Pub. L. 94-455 applicable to taxable years beginning after Dec. 31, 1975, with certain exceptions, and the provisions of subsec. (g) not to apply to any tax im- posed by a possession of the United Sttcs with re- spect to the complete liquidation occurring before Jan. 1, 1979, of a corporation to the extent that such tax is attributable to earnings and profits accumulated by such corporation during periods ending before Jan. 1, 1976, see section 1051(d) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under sec- tion 33 of this title. Amendment of subsecs. (a), (g)(3) by section 1901(b)(1)(H)(iii), (37)(A) of Pub. L. 94-455 applicable with respect to 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 sec- tion 2 of this title. EFFECTIVE DATE OF 1975 AMENDMENT Amendment by Pub. L. 94-12 applicable to taxable years ending after Dec. 31, 1974, see section 601(d) of Pub. L. 94-12, set out as an Effective Date note under section 907 of this title. EFFECTIVE DATE OF 1974 AMENDMENT Amendment of subsec. (a) by section 2001(g)(2)(C) of Pub. L. 93-406, which inserted reference to the tax im- posed for the taxable year under section 72(m)(5)(B) (relating to 10 percent tax on premature distributions to owner-employees), applicable to distributions made in taxable years beginning after Dec. 31, 1975, see sec- tion 2001(i)(4) of Pub. L. 93-406, set out as an Effec. tive Date of 1974 Amendment note under section 72 of this title. Amendment of subsec. (a) by section 2002(g)(3) of Pub. L. 93-406, which inserted reference to the tax im- posed for the taxable year by section 408(f) (relating to additional tax on income from certain retirement accounts), effective on Jan. 1, 1975, see section 2002(i)(2) of Pub. L. 93-406, set out as an Effective Date note under section 4973 of this title. Amendment of subsec. (a) by section 2005(c)(5) of Pub. L. 93-406, which inserted reference to the tax im- posed for the taxable year under section 402(e) (relat- ing to tax on lump sum distributions), applicable only with respect to distributions or payments made after Dec. 31, 1973. in taxable years beginning after Dec. 31, 1973, see section 2005(d) of Pub. L. 93-406, set out as an Effective Date of 1974 Amendment note under sec- tion 402 of this title. EFFECTIVE DATE OF 1971 AMENDMENT Enactment of subsec. (d) by Pub. L. 92-178 applica- ble with respect to taxable years ending after Dec. 31, 1971, except that a corporation may not be a DISC for any taxable year beginning before Jan. 1, 1972, see sec- tion 507 of Pub. L. 92-178, set out as an Effective Date note under section 991 of this title. EFFECTIVE DATE OF 1969 AMENDMENT Section 506(c) of Pub. L. 91-172 provided that: "The amendments made by this section [amending this sec- tion and section 904 of this title] shall apply with re- spect to taxable years beginning after December 31, 1969." Amendment of subsec. (a) by section 301(b)(9) of Pub. L. 91-172 applicable to taxable years ending after Dec. 31, 1969, see section 301(c) of Pub. L. 91-172, set out as an Effective Date note under section 56 of this title. EFFECTIVE DATE OF 1966 AMENDMENT Amendment of subsec. (a) by Pub. L. 89-384 applica- ble with respect to amounts received after December 31, 1964, in respect of foreign expropriation losses (as defined in section 1351(b) of this title) sustained after December 31, 1958, see section 2 of Pub. L. 89-384, set Page 577