26 USC § 27 - Taxes of foreign countries and possessions of the United States

---
identifier: "/us/usc/t26/s27"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 27 - Taxes of foreign countries and possessions of the United States"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "27"
section_name: "Taxes of foreign countries and possessions of the United States"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "A"
subchapter_name: "Determination of Tax Liability"
part_number: "IV"
part_name: "CREDITS AGAINST TAX"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Aug. 16, 1954, ch. 736, 68A Stat. 13, § 33; Pub. L. 94–455, title X, § 1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered § 27, Pub. L. 98–369, div. A, title IV, § 471(c), July 18, 1984, 98 Stat. 826; Pub. L. 115–141, div. U, title IV, § 401(d)(1)(A), Mar. 23, 2018, 132 Stat. 1206.)"
---


# 1 Taxes of foreign countries and possessions of the United States

So in original. Probably should be followed by a period.

[^1]

The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901

---

**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 13, § 33; Pub. L. 94–455, title X, § 1051(a), Oct. 4, 1976, 90 Stat. 1643; renumbered § 27, Pub. L. 98–369, div. A, title IV, § 471(c), July 18, 1984, 98 Stat. 826; Pub. L. 115–141, div. U, title IV, § 401(d)(1)(A), Mar. 23, 2018, 132 Stat. 1206.)

## Editorial Notes

### Amendments

2018— amended section generally. Prior to amendment, section consisted of subsecs. (a) and (b) relating to the foreign tax credit under section 901 and the tax credit under section 936, respectively.

1984—, renumbered  as this section.

1976— designated existing provisions as subsec. (a) and added subsec. (b).

## Statutory Notes and Related Subsidiaries

### Effective Date of 1976 Amendment

> **“(1)** Except as provided by paragraph (2), the amendments made by this section [enacting section 936 of this title and amending sections 33 [now 27], 48, 116, 243, 246, 861, 901, 904, 931, 1504, and 6091 of this title] shall apply to taxable years beginning after December 31, 1975, except that ‘qualified possession source investment income’ as defined in [former] section 936(d)(2) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] shall include income from any source outside the United States if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or his delegate that the income from such sources was earned before October 1, 1976.
> 
> **“(2)** The amendment made by subsection (d)(2) [amending section 901 of this title] shall not apply to any tax imposed by a possession of the United States with respect to the complete liquidation occurring before January 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 January 1, 1976.”

, , , as amended by , , , provided that:

### Savings Provision

For provisions that nothing in amendment by  be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to , for purposes of determining liability for tax for periods ending after , see , set out as a note under .