qualifying dividend

(1) In general For purposes of this section, the term “qualifying dividend” means any dividend received by a corporation— (A) if at the close of the day on which such dividend is received, such corporation is a member of the same affiliated group as the corporation distributing such dividend, and (B) if such dividend is distributed out of the earnings and profits of a taxable year of the distributing corporation which ends after December 31, 1963 , and on each day of which the distributing corporation and the corporation receiving the dividend were members of such affiliated group.


26 USC § 243(b)(1)

Scoping language

For purposes of this section
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