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26 U.S.C. · Internal Revenue Code
26 U.S.C. § 1358

Allocation of credits, income, and deductions

Ch. 1 — NORMAL TAXES AND SURTAXES
Title 26 U.S.C. ● ACTIVE Primary Source Ch. 1
Statutory Text

26 U.S.C. § 1358 — Allocation of credits, income, and deductions

U.S.C. Title 26 - INTERNAL REVENUE CODE 26 U.S.C. United States Code, 2023 Edition Title 26 - INTERNAL REVENUE CODE Subtitle A - Income Taxes CHAPTER 1 - NORMAL TAXES AND SURTAXES Subchapter R - Election To Determine Corporate Tax on Certain International Shipping Activities Using Per Ton Rate Sec. 1358 - Allocation of credits, income, and deductions From the U.S. Government Publishing Office, www.gpo.gov

§1358. Allocation of credits, income, and deductions

(a) Qualifying shipping activities For purposes of this chapter, the qualifying shipping activities of an electing corporation shall be treated as a separate trade or business activity distinct from all other activities conducted by such corporation. (b) Exclusion of credits or deductions (1) No deduction shall be allowed against the notional shipping income of an electing corporation, and no credit shall be allowed against the tax imposed by section 1352(2). (2) No deduction shall be allowed for any net operating loss attributable to the qualifying shipping activities of any person to the extent that such loss is carried forward by such person from a taxable year preceding the first taxable year for which such person was an electing corporation. (c) Transactions not at arm's length Section 482 applies in accordance with this subsection to a transaction or series of transactions— (1) as between an electing corporation and another person, or (2) as between a person's qualifying shipping activities and other activities carried on by it.

(Added Pub. L. 108–357, title II, §248(a), Oct. 22, 2004, 118 Stat. 1456; amended Pub. L. 115–141, div. U, title IV, §401(a)(188), (189), Mar. 23, 2018, 132 Stat. 1193.)

Editorial Notes

Amendments 2018—Subsec. (b)(1). Pub. L. 115–141, §401(a)(188), substituted "section 1352(2)" for "section 1352(a)(2)". Subsec. (c)(2). Pub. L. 115–141, §401(a)(189), substituted "a person's" for "an person's".

Statutory Notes and Related Subsidiaries

Effective Date Section applicable to taxable years beginning after Oct. 22, 2004, see section 248(c) of Pub. L. 108–357, set out as an Effective Date of 2004 Amendments note under section 56 of this title.

Source: uscode.house.gov — public domain Official Source ↗
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26 U.S.C. § 1358
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The statutory text of 26 U.S.C. § 1358 is reproduced from the official United States Code as published by the Office of the Law Revision Counsel of the U.S. House of Representatives (uscode.house.gov).
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