No credit is given for 10 percent of foreign tax on certain payouts
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70312, Sec. 70312.
Written by .
No credit is given for 10 percent of foreign tax on certain payouts
The document says “shall not”Who acts: Secretary of the TreasuryHow: statuteSec. 70312 in the PDF
What the document says
“No credit shall be allowed under section 901 for 10 percent of any foreign income taxes paid or accrued (or deemed paid under subsection (b)(1)) with respect to any amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a).”
The section adds a new paragraph (4) to section 960(d) of the Internal Revenue Code of 1986 barring a credit under section 901 for 10 percent of foreign income taxes paid, accrued or deemed paid on an amount excluded from gross income under section 959(a) because of an inclusion under section 951A(a).
What the document actually says
“No credit shall be allowed under section 901 for 10 percent of any foreign income taxes paid or accrued (or deemed paid under subsection (b)(1)) with respect to any amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a).”
That sentence, in plain words
No credit is given for a tenth of the foreign tax. That is tax on money already taxed once and paid out later.
What this is about
The other nine tenths may still be claimed. The rule reaches tax paid and tax treated as paid. The tax code is not indexed here.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70312, 139 Stat. 203 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“No credit is given for 10 percent of foreign tax on certain payouts,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70312, Sec. 70312. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70312-disallowance/ (retrieved October 10, 2026).
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