aggregate foreign E&P deficit
Defined in 1 place of the United States Code.
The term "aggregate foreign E&P deficit" means, with respect to any United States shareholder, the lesser of—
(I) the aggregate of such shareholder's pro rata shares of the specified E&P deficits of the E&P deficit foreign corporations of such shareholder, or
(II) the amount determined under paragraph (2)(B).
Source
- 2017–present26 U.S.C. § 965Internal Revenue Code · Temporary dividends received deduction · in this section