post-1986 earnings and profits
Defined in 2 places of the United States Code.
For purposes of clause (i), the term “post-1986 earnings and profits” means earnings and profits which were accumulated in taxable years of such company beginning after December 31, 1986, and during the period or periods the stock was held by the taxpayer while the company was a passive foreign investment company.
Source
- 1994–present26 U.S.C. § 1291Internal Revenue Code · Interest on tax deferral · for purposes of this section
The term "post-1986 earnings and profits" means the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986, and by only taking into account periods when the foreign corporation was a specified foreign corporation) accumulated in taxable years beginning after December 31, 1986, and determined—
(A) as of the date referred to in paragraph (1) or (2) of subsection (a), whichever is applicable with respect to such foreign corporation, and
(B) without diminution by reason of dividends distributed during the taxable year described in subsection (a) other than dividends distributed to another specified foreign corporation.
Source
- 2017–present26 U.S.C. § 965Internal Revenue Code · Temporary dividends received deduction · for purposes of this section