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post-1986 undistributed earnings

Defined in 2 places of the United States Code.

The term "post-1986 undistributed earnings" means the amount of the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986) accumulated in taxable years beginning after December 31, 1986—

(A) as of the close of the taxable year of the foreign corporation in which the dividend is distributed, and

(B) without diminution by reason of dividends distributed during such taxable year.

Same definition in 2 sections

  • 2017–present26 U.S.C. § 245Internal Revenue Code · Dividends received from certain foreign corporations · in this section
  • 1994–present26 U.S.C. § 902Internal Revenue Code · Deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation · for purposes of this subpart

For purposes of this subsection, the term “post-1986 undistributed earnings” has the meaning given to such term by section 902(c)(1).

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