Recapture account.

(i) Recapture account. If a category of subpart F income described in section 952(a) or, in the case of foreign base company income, described in 1.954-1(c)(1)(iii)(A) (1) or (2) is reduced under the current year earnings and profits limitation of section 952(c)(1)(A) and paragraph (e) of this section for a taxable year, the amount of such reduction shall constitute a recapture account.

Source

26 CFR § 1.952-1


Scoping language

None
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