E&P deficit foreign corporation
Defined in 1 dictionary — U.S. Code
United States Code
26 U.S.C. § 965 — in this section
The term "E&P deficit foreign corporation" means, with respect to any taxpayer, any specified foreign corporation with respect to which such taxpayer is a United States shareholder, if, as of November 2, 2017—
(i) such specified foreign corporation has a deficit in post-1986 earnings and profits,
(ii) such corporation was a specified foreign corporation, and
(iii) such taxpayer was a United States shareholder of such corporation.