§176 — Payments with respect to employees of certain foreign corporations
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Statute Text — 26 U.S.C. §176
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.
7 Citing Cases
If State law governs, either independently or because Federal common law so dictates,8 we must decide which State law, and that is a choice-of-law question. In this case, we have jurisdiction under the Internal Revenue Code. Therefore Federal common law applies to the choice-of-law rule determination, and this means applying the approach
If State law governs, either independently or because Federal common law so dictates,8 we must decide which State law, and that is a choice-of-law question. In this case, we have jurisdiction under the Internal Revenue Code. Therefore Federal common law applies to the choice-of-law rule determination, and this means applying the approach
4 (2001). Thus, under 20 C.F.R. sec. 404.408(b)(2) (2001), petitioner's Social Security benefits should not have been reduced by a workers' compensation - 5 - offset because petitioner's workers' compensation benefits were offset by Social Security benefits after May 2, 1996. The workers' compensation benefits were reduced by