E&P net deficit shareholder
Defined in 1 dictionary — U.S. Code
United States Code
26 U.S.C. § 965 — in this section
For purposes of this paragraph, the term "E&P net deficit shareholder" means any United States shareholder if—
(i) the aggregate foreign E&P deficit with respect to such shareholder (as defined in paragraph (3)(A) without regard to clause (i)(II) thereof), exceeds
(ii) the amount which would (but for this subsection) be taken into account by such shareholder under section 951(a)(1) by reason of subsection (a).