Title 26, Internal Revenue CodeRelease 119-102
§176 Payments with Respect to Employees of Certain Foreign Corporations
Title 26 › Subtitle A — Income Taxes › CHAPTER 1 — NORMAL TAXES AND SURTAXES › Subchapter B — Computation of Taxable Income › PART VI — ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS › § 176
Summary
U.S. companies may deduct payments under section 3121(l) for U.S. citizens who work for their foreign subsidiaries; any reimbursements must be included in gross income when received.
Full Legal Text
Title 26, §176
Internal Revenue Code, Source: USLM XML via OLRC
In the case of a domestic corporation, there shall be allowed as a deduction amounts (to the extent not compensated for) paid or incurred pursuant to an agreement entered into under section 3121(l) with respect to services performed by United States citizens employed by foreign subsidiary corporations. Any reimbursement of any amount previously allowed as a deduction under this section shall be included in gross income for the taxable year in which received.
Reference
Citations & Metadata
Citation
26 U.S.C. § 176
Title 26, Internal Revenue Code
Last Updated
Aug 21, 2026
Release point: 119-102