undistributed foreign earnings
Defined in 1 place of the United States Code.
The term "undistributed foreign earnings" means the portion of the undistributed earnings which is attributable to neither—
(A) income described in subparagraph (A) of section 245(a)(5), nor
(B) dividends described in subparagraph (B) of such section (determined without regard to section 245(a)(12)).
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