26 USC § 176 - Payments with respect to employees of certain foreign corporations

---
identifier: "/us/usc/t26/s176"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 176 - Payments with respect to employees of certain foreign corporations"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "176"
section_name: "Payments with respect to employees of certain foreign corporations"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "B"
subchapter_name: "Computation of Taxable Income"
part_number: "VI"
part_name: "ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Added Sept. 1, 1954, ch. 1206, title II, § 210(a), 68 Stat. 1096.)"
---


# § 176. Payments with respect to employees of certain foreign corporations

*l*

In the case of a domestic corporation, there shall be allowed as a deduction amounts (to the extent not compensated for) paid or incurred pursuant to an agreement entered into under section 3121() with respect to services performed by United States citizens employed by foreign subsidiary corporations. Any reimbursement of any amount previously allowed as a deduction under this section shall be included in gross income for the taxable year in which received.

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**Source Credit**: (Added Sept. 1, 1954, ch. 1206, title II, § 210(a), 68 Stat. 1096.)