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(c) Allowance of Deductions and Credits.--
(1) Deductions allowed only if return
filed.--A foreign corporation shall receive
the benefit of the deductions allowed to it
in this subtitle only by filing or causing to
be filed with the Secretary or his delegate a
true and accurate return of its total income
received from all sources in the United
States, in the manner prescribed in subtitle
F, including therein all the information
which the Secretary or his delegate may deem
necessary for the calculation of such
deductions.
The House committee report underlying the 1954 Code stated as to
this action: “Subsection (c), relating to necessity for filing
of returns by foreign corporations in order to secure allowance
of deductions and credits, is, in substance, identical with
sections 232, 233, and 234, 1939 Code.” H. Rept. 1337, 83d
Cong., 2d Sess. A246 (1954); see also S. Rept. 1622, 83d Cong.,
2d Sess. 417 (1954) (same statement except omits the words “and
credits”).
Section 882 of the 1954 Code was next amended in the Foreign
Investors Tax Act of 1966, Pub. L. 89-809, sec. 104(b)(1), 80
Stat. 1555. A stated purpose of that act was “To provide
equitable tax treatment for foreign investment in the United
States”. Foreign Investors Tax Act of 1966, 80 Stat. 1539. To
that end, Congress renumbered section 882(c)(1) of the 1954 Code
with slight modification as section 882(c)(2) and added a new
section 882(d). Foreign Investors Tax Act of 1966, sec.
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