26 U.S.C. § 176 — Payments with respect to employees of certain foreign corporations

submitted 72 years ago by ch. 1206 to r/title-26-INTERNAL-REVENUE-CODE · 75 words · no verdicts yet

in plain englishAI-generated · not legal advice

A U.S. corporation can deduct payments it makes for U.S. citizens who work for its foreign subsidiaries, if those payments follow a specific Social Security agreement. If the company later gets reimbursed for that deduction, it must count the reimbursement as income.

In the case of a domestic corporation, a deduction is allowed for amounts (to the extent not otherwise compensated for) that the corporation pays or incurs under an agreement entered into under section 3121(l), covering services performed by United States citizens employed by the corporation's foreign subsidiary corporations. If the corporation is later reimbursed for any amount it already claimed as a deduction under this section, it must include that reimbursement in its gross income for the tax year it's received.

the actual law source: uscode.house.gov ↗public domain

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(l) 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.

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

history & why it existsrecord from the source credit

1954Enacted · Act of Sept. 1, 1954, ch. 1206 · 68 Stat. 1096

A history note hasn’t been published yet. The record shows enactment by ch. 1206 on 1954-09-01.

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