§908 — Reduction of credit for participation in or cooperation with an international boycott

18 cases·18 cited

(a)In general

If a person, or a member of a controlled group (within the meaning of section 993(a)(3)) which includes such person, participates in or cooperates with an international boycott during the taxable year (within the meaning of section 999(b)), the amount of the credit allowable under section 901 to such person, or under section 960 to United States shareholders of such person, for foreign taxes paid during the taxable year shall be reduced by an amount equal to the product of—

(1)

the amount of the credit which, but for this section, would be allowed under section 901 for the taxable year, multiplied by

(2)

the international boycott factor (determined under section 999).

(b)Application with sections 275(a)(4) and 78

Section 275(a)(4) and section 78 shall not apply to any amount of taxes denied credit under subsection (a).

18 Citing Cases

David W. Tice, Petitioner 160 T.C. No. 8 · 2023

5 It also provides that the working arrangement announced in I.R.S.

Anthony R. Tanner, Deceased, Petitioner T.C. Memo. 2023-54 · 2023

108-357, § 908(c)(2), 118 Stat.

he statute was amended by striking "at the close of the taxable year" and inserting "during the entire taxable year" each I place it appears, effective for tax years ending after October 22, 2004. American Jobs Creation Act of 2004, Pub. L. 108-357, sec. 908(c) (2), (d), 118 Stat. 1656, 1657. - 5 - An individual who is a bona fide resident of the Virgin Islands and incurs income tax obligations to both the United States and the Virgin Islands may satisfy his reporting and payment requirements by

Nield & Linda Montgomery, Petitioner 122 T.C. No. 1 · 2004

6311(d) (3) (C) provides in relevant part that "a payment of internal revenue taxes * * * by use of a debit card shall not be subject to section 908 of the Electronic Fund Transfer Act * * * if the error alleged by the person is an error relating to the underlying tax liability".

Estate of Sanders v. Commissioner 144 T.C. 63 · 2015
Montgomery v. Commissioner 122 T.C. 1 · 2004
Horton v. Commissioner 100 T.C. 93 · 1993
United States v. Morgan · Cir.
Jay Isaac Hollis v. Loretta Lynch 827 F.3d 436 · Cir.
Jose Guzman Gonzalez v. Jefferson Sessions III 894 F.3d 131 · Cir.

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