Deductions From Gross Income for Payments With Respect to Employees of Certain Foreign Corporations

Deductions From Gross Income for Payments With Respect to Employees of Certain Foreign Corporations Sec. 210. (a) The Internal Revenue Code of 1954 is amended by inserting after section 175 thereof the following new section: “SEC. 176. PAYMENTS WITH RESPECT TO EMPLOYEES OF CERTAIN FOREIGN CORPORATIONS. “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 (1) with respect to services performed by United States citizens employed by foreign subsidiary corporations. Any reimbursement of any 68 Stat. 1097amount previously allowed as a deduction under this section shall be included in gross income for the taxable year in which received.” (b) The table of sections to part VI of subchapter B of chapter 1 of subtitle A of the Internal Revenue Code of 1954 is amended by adding at the end thereof the following: “Sec. 176. Payments with respect to employees of certain foreign corporations.”