FOREIGN TAX CREDIT WITH RESPECT TO CERTAIN FOREIGN MINERAL INCOME.

SEC. 506. FOREIGN TAX CREDIT WITH RESPECT TO CERTAIN FOREIGN MINERAL INCOME. (a) Limitation on Amount of Foreign Taxes Allowed.—Section 901 (relating to taxes of foreign countries and possessions of the United States) is amended— (1) by redesignating subsection (e) as subsection (f), and (2) by inserting after subsection (d) the following new subsection: “(e) Foreign Taxes on Mineral Income.— “(1) Reduction in amount allowed.—Notwithstanding subsection (b), the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or possession of the United States with respect to foreign 83 Stat. 635 mineral income from sources within such country or possession which would (but for this paragraph) be allowed under such subsection shall be reduced by the amount (if any) by which— “(A) the amount of such taxes (or, if smaller, the amount of the tax which would be computed under this chapter with respect to such income determined without the deduction allowed under section 613), exceeds “(B) the amount of the tax computed under this chapter with respect to such income. “(2) Foreign mineral income defined.—For purposes of paragraph (1), the term ‘foreign mineral income’ means income derived from the extraction of minerals from mines, wells, or other natural deposits, the processing of such minerals into their primary products, and the transportation, distribution, or sale of such minerals or primary products. Such term includes, but is not limited to— “(A) dividends received from a foreign corporation in respect of which taxes are deemed paid by the taxpayer under section 902, to the extent such dividends are attributable to foreign mineral income, and “(B) that portion of the taxpayer’s distributive share of the income of partnerships attributable to foreign mineral income” (b) Election of Overall Limitation.—Section 904(b) (relating election of overall limitation) is amended— (1) by striking out “with the consent of the Secretary or his delegate with respect to any taxable year” in paragraph (1) and inserting in lieu thereof “(A) with the consent of the Secretary or his delegate with respect to any taxable year or (B) for the taxpayer’s first taxable year beginning after December 31, 1969”, and (2) by striking out “If a taxpayer” in paragraph (2) and inserting in lieu thereof “Except in a case to which paragraph (1)(B) applies, if the taxpayer”. (c) Effective Date.—The amendments made by this section shall apply with respect to taxable years beginning after December 31, 1969.