unreversed inclusions
Defined in 1 place of the United States Code.
For purposes of this section, the term "unreversed inclusions" means, with respect to any stock in a passive foreign investment company, the excess (if any) of—
Source
- 1997–present26 U.S.C. § 1296Internal Revenue Code · Election of mark to market for marketable stock · for purposes of this section
For purposes of this section, the term “unreversed inclusions” means, with respect to any stock in a passive foreign investment company, the excess (if any) of—
(1) the amount included in gross income of the taxpayer under subsection (a)(1) with respect to such stock for prior taxable years, over
(2) the amount allowed as a deduction under subsection (a)(2) with respect to such stock for prior taxable years.
Source
- 201326 U.S.C. § 1296Internal Revenue Code · Election of mark to market for marketable stock · for purposes of this section