undistributed earnings
Defined in 2 places of the United States Code.
The term "undistributed earnings" means the amount of the earnings and profits of the specified 10-percent owned foreign corporation (computed in accordance with sections 964(a) and 986)—
(A) as of the close of the taxable year of the specified 10-percent owned foreign corporation in which the dividend is distributed, and
(B) without diminution by reason of dividends distributed during such taxable year.
Source
- 2017–present26 U.S.C. § 245AInternal Revenue Code · Deduction for foreign source-portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations · for purposes of this section
The term “undistributed earnings” means, with respect to any qualified electing fund, the excess (if any) of—
(A) the amount includible in gross income by reason of section 1293(a) for the taxable year, over
(B) the amount not includible in gross income by reason of section 1293(c) for such taxable year.
Source
- 1994–present26 U.S.C. § 1294Internal Revenue Code · Election to extend time for payment of tax on undistributed earnings · for purposes of this section