§ 1358 - Allocation of credits, income, and deductions

CHAPTER 1— NORMAL TAXES AND SURTAXES › Subchapter R— Election To Determine Corporate Tax on Certain International Shipping Activities Using Per Ton Rate

(a) 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)(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).

(b)(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)(1) as between an electing corporation and another person, or

(c)(2) as between a person’s qualifying shipping activities and other activities carried on by it.

Notes

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.