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TITLE 26-INTERNAL REVENUE CODE fective Date of 1969 Amendment note under section 901 of this title. EFFECTIVE DATE OF 1966 AMENDMENT Section 106(c)(2) of Pub. L. 89-809 provided that: "The amendments made by paragraph (1) [amending subsec. (f)(2)) shall apply to interest received after De- cember 31, 1965, in taxable years ending after such date." EFFECTIVE DATE OF 1964 AMENDMENT Amendment by Pub. L. 88-272 applicable to taxable years beginning after Dec. 31, 1963, see section 234(c) of Pub. L. 88-272, set out as an Effective Date of 1964 Amendment note under section 1503 of this title. EFFECTIVE DATE OF 1962 AMENDMENT Section 10(b) of Pub. L. 87-834 provided that: "The amendments made by subsection (a) (redesignating subsec. (f) as (g) and adding subsec. (f)] shall apply with respect to taxable years beginning after the date of the enactment of this Act [Oct. 16, 19621, but only with respect to interest resulting from transactions consummated after April 2, 1962." EFFECTIVE DATE OF 1960 AMENDMENT Section 4 of Pub. L. 86-780 provided that: "The amendments made by the first section [amending this section], section 2 (amending section 1503(d) of this title], and subsection (a) of section 3 of this Act [amending section 901(a), (b) of this title] shall apply with respect to taxable years beginning after Decem. ber 31, 1960. The amendment made by subsection (b) of section 3 of this Act (amending section 901(a) of this title] shall apply with respect to taxable years be- ginning after December 31, 1953, and ending after August 16, 1954. The amendments made by subsection (c) of section 3 of this Act [adding section 6501(i) of this title] shall apply with respect to taxable years be. ginning after December 31, 1957." EFFECTIVE DATE OF 1958 AMENDMENT Section 42(c) of Pub. L. 85-866 provided that: "The amendments made by subsections (a) and (b) [adding subsec. (c) of this section and amending section 6611(g)(h) of this title] shall apply only with respect to taxable years beginning after December 31, 1957." SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 383, 841, 901, 906, 907, 936, 960. 6038, 6501 of this title. § 905. Applicable rules (a) Year in which credit taken The credits provided in this subpart may, at the option of the taxpayer and irrespective of the method of accounting employed in keeping his books, be taken in the year in which the taxes of the foreign country or the possession of the United States accrued, subject, however, to the conditions prescribed in subsection (c). If the taxpayer elects to take such credits in the year in which the taxes of the foreign country or the possession of the United States accrued, the credits for all subsequent years shall be taken on the same basis, and no portion of any such taxes shall be allowed as a deduction in the same or any succeeding year. (b) Proof of credits The credits provided in this subpart shall be allowed only if the taxpayer establishes to the satisfaction of the Secretary- (1) the total amount of income derived from sources without the United States, deter- mined as provided in part I, (2) the amount of income derived from each country, the tax paid or accrued to which is claimed as a credit under this subpart, such amount to be determined under regulations prescribed by the Secretary, and (3) all other information necessary for the verification and computation of such credits, (c) Adjustments on payment of accrued taxes If accrued taxes when paid differ from the amounts claimed as credits by the taxpayer, or if any tax paid is refunded in whole or in part, the taxpayer shall notify the Secretary, who shall redetermine the amount of the tax for the year or years affected. The amount of tax due on such redetermination, if any, shall be paid by the taxpayer on notice and demand by the Secretary, or the amount of tax overpaid, if any, shall be credited or refunded to the tax- payer in accordance with subchapter B of chap- ter 66 (see. 6511 and following). In the case of such a tax accrued but not paid, the Secretary, as a condition precedent to the allowance of this credit, may require the taxpayer to give a bond, with sureties satisfactory to and to be ap- proved by the Secretary, in such sum as the Secretary may require, conditioned on the pay- ment by the taxpayer of any amount of tax found due on any such redetermination; and the bond herein prescribed shall contain such further conditions as the Secretary may re- quire. In such redetermination by the Secretary of the amount of tax due from the taxpayer for the year or years affected by a refund, the amount of the taxes refunded for which credit has been allowed under this section shall be re- duced by the amount of any tax described in section 901 imposed by the foreign country or possession of the United States with respect to such refund; but no credit under this subpart, and no deduction under section 164 (relating to deduction for taxes) shall be allowed for any taxable year with respect to such tax imposed on the refund. No interest shall be assessed or collected on any amount of tax due on any re- determination by the Secretary, resulting from a refund to the taxpayer, for any period before the receipt of such refund, except to the extent interest was paid by the foreign country or pos- session of the United States on such refund for such period. (Aug. 16, 1954, ch. 736, 68A Stat. 288; Sept. 2, 1958, Pub. L. 85-866, title I, § 103(b), 72 Stat. 1675; Oct. 4, 1976, Pub. L. 94-455, title XIX, §§ 1901(a)(114), 1906(b)(13)(A), 90 Stat. 1784, 1834.) AMENDMENTS 1976-Subsec. (bW. Pub. L. 94-455, §§ 1901(a)(114), 1906(b)(13)(A), struck out provision allowing credits to be taken for tax on royalties paid, accrued and derived from sources within the United Kingdom of Britain and Northern Ireland and struck out "or his delegate" following "Secretary", in two places. Subsec. (c). Pub. L. 94-455, § 1906(b)(13)(A), struck out "or his delegate" following "Secretary" in eight places. 1958-Subsec. (b). Pub. L. 85-866 added sentence deeming recipient of a royalty or other amount for use of copyright, patent, and other like property derived from sources within United Kingdom, to have paid or accrued taxes paid or accrued to United Kingdom with respect to royalty if recipient elects to include in its gross income the amount of such United Kingdom tax. Page 585 § 905