Intel Corporation and Consolidated Subsidiaries - Page 10

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          1639, it also enacted section 6611(g) (now section 6611(f)(2))              
          which provided:                                                             
               if any overpayment of tax results from a carryback of                  
               tax paid or accrued to foreign countries or possessions                
               of the United States, such overpayment shall be deemed                 
               not to have been paid or accrued prior to the close of                 
               the taxable year under this subtitle in which such                     
               taxes were in fact paid or accrued.[4] [Technical                      
               Amendments Act of 1958, Pub. L. 85-866, sec. 42(b), 72                 
               Stat. 1640.]                                                           
          The legislative history sheds little light on the question now              
          before us.  Beyond reiterating the above provisions, such history           
          addresses only:  (1) The purpose of section 904(c), i.e.,  to               
          eliminate the double taxation that could result from timing                 
          differences between the methods of reporting income of the United           
          States and the foreign country and the foreign tax credit                   
          limitations existing at that time; and (2) the mechanics of                 
          determining the amounts of the foreign tax carryback and                    
          carryover to be applied to the appropriate years specified in               
          section 904(c).  H. Rept. 775, 85th Cong., 1st Sess. (1957),                
          1958-3 C.B. 811, 837-838, 892-895.                                          
               Congress did not include in the 1958 legislation a                     
          provision, like the one it had enacted in 1954 for net operating            

          4  Sec. 6611(g) was amended, effective for interest accruing                
          after Oct. 3, 1982, to replace "the close of the taxable year"              
          with "the filing date (as defined in subsection (f)(3)) for the             
          taxable year".  Tax Equity and Fiscal Responsibility Act of 1982,           
          Pub. L. 97-248, sec. 346(c)(1)(D), 96 Stat. 637.  Sec. 6611(f)(3)           
          defines "filing date" as the last date prescribed for filing the            
          return, without regard to extensions.  See also discussion infra            
          pp. 22-23.                                                                  




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