accumulated effectively connected earnings and profits
Defined in 1 place of the United States Code.
For purposes of clause (i), the term “accumulated effectively connected earnings and profits” means the excess of—
(I) the aggregate effectively connected earnings and profits for preceding taxable years beginning after December 31, 1986, over
(II) the aggregate dividend equivalent amounts determined for such preceding taxable years.
For purposes of this section—
(1) In general
Source
- 1994–present26 U.S.C. § 884Internal Revenue Code · Branch profits tax · in this section