§ 853. Foreign tax credit allowed to shareholders
(a)
General rule
A regulated investment company—
(b)
Effect of election
If the election provided in subsection (a) is effective for a taxable year—
(1)
the regulated investment company—
(2)
each shareholder of such investment company shall—
(B)
treat as gross income from sources within the respective foreign countries and possessions of the United States, for purposes of applying subpart A of part III of subchapter N, the sum of his proportionate share of such taxes and the portion of any dividend paid by such investment company which represents income derived from sources within foreign countries or possessions of the United States.
(c)
Statements to shareholders
The amounts to be treated by the shareholder, for purposes of subsection (b)(2), as his proportionate share of—
(2)
gross income derived from sources within any foreign country or possession of the United States,
shall not exceed the amounts so reported by the company in a written statement furnished to such shareholder.
(d)
Manner of making election
The election provided in subsection (a) shall be made in such manner as the Secretary may prescribe by regulations.
(e)
Treatment of certain taxes not allowed as a credit under section
901
This section shall not apply to any tax with respect to which the regulated investment company is not allowed a credit under section
901 by reason of subsection (k) or (l) of such section.
(f)
Cross references