Swallows Holding, Ltd. - Page 65

                                        -21-                                          
                    (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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