Title 26, Internal Revenue CodeRelease 119-102
§515 Taxes of Foreign Countries and Possessions of the United States
Title 26 › Subtitle A — Income Taxes › CHAPTER 1 — NORMAL TAXES AND SURTAXES › Subchapter F — Exempt Organizations › PART III — TAXATION OF BUSINESS INCOME OF CERTAIN EXEMPT ORGANIZATIONS › § 515
Summary
Organizations taxed under section 511 can credit foreign taxes against their U.S. tax under section 901. In that rule, "taxable income" in section 901 means "unrelated business taxable income."
Full Legal Text
Title 26, §515
Internal Revenue Code, Source: USLM XML via OLRC
The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax of an organization subject to the tax imposed by section 511 to the extent provided in section 901; and in the case of the tax imposed by section 511, the term “taxable income” as used in section 901 shall be read as “unrelated business taxable income”.
Reference
Citations & Metadata
Citation
26 U.S.C. § 515
Title 26, Internal Revenue Code
Last Updated
Aug 21, 2026
Release point: 119-102