United States source ratio
Defined in 1 place of the United States Code.
For purposes of subparagraph (A), the term “United States source ratio” means, with respect to any dividend paid out of the earnings and profits for any taxable year, a fraction—
(i) the numerator of which is the portion of the earnings and profits for such taxable year from sources within the United States, and
(ii) the denominator of which is the total amount of earnings and profits for such taxable year.
Source
- 1994–present26 U.S.C. § 904Internal Revenue Code · Limitation on credit · for purposes of this section