Denial of foreign tax credit with respect to the Russian Federation

(a) In general Section 901(j)(2) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (C) Special rule for Russia (i) In general This subsection shall apply to the Russian Federation during the period described in clause (ii). (ii) Period of application The period described in this clause with respect to any country is the period— (I) beginning on the date that is 30 days after the date of the enactment of this subparagraph, and (II) ending on the date on which the resumption of the application of the rates of duty set forth in column 1 of the Harmonized Tariff Schedule of the United States to products of that country takes effect pursuant to section 4(b) of the Suspending Normal Trade Relations with Russia and Belarus Act.. (b) Deduction denied Section 901(j)(3) of such Code is amended by adding at the end the following new sentence: The preceding sentence shall not apply to any tax of any country to which paragraph (2)(C) applies.. (c) Effective dates (1) In general Except as provided in paragraph (2), the amendments made by this section shall take effect on the date of the enactment of this Act. (2) Deduction limitation The amendment made by subsection (b) shall apply to taxes paid or accrued (or deemed paid or accrued under section 960 of the Internal Revenue Code of 1986) after the date that is 90 days after the date of the enactment of this Act. (3) Nonapplication of treaty rules This section and the amendments made by this section shall be applied without regard to any treaty obligation of the United States.

(a) In general Section 901(j)(2) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (C) Special rule for Russia (i) In general This subsection shall apply to the Russian Federation during the period described in clause (ii). (ii) Period of application The period described in this clause with respect to any country is the period— (I) beginning on the date that is 30 days after the date of the enactment of this subparagraph, and (II) ending on the date on which the resumption of the application of the rates of duty set forth in column 1 of the Harmonized Tariff Schedule of the United States to products of that country takes effect pursuant to section 4(b) of the Suspending Normal Trade Relations with Russia and Belarus Act.. (b) Deduction denied Section 901(j)(3) of such Code is amended by adding at the end the following new sentence: The preceding sentence shall not apply to any tax of any country to which paragraph (2)(C) applies.. (c) Effective dates (1) In general Except as provided in paragraph (2), the amendments made by this section shall take effect on the date of the enactment of this Act. (2) Deduction limitation The amendment made by subsection (b) shall apply to taxes paid or accrued (or deemed paid or accrued under section 960 of the Internal Revenue Code of 1986) after the date that is 90 days after the date of the enactment of this Act. (3) Nonapplication of treaty rules This section and the amendments made by this section shall be applied without regard to any treaty obligation of the United States.