effectively connected earnings and profits

(2)The term “effectively connected earnings and profits” shall not include any earnings and profits attributable to— (A)income not includible in gross income under paragraph (1) or (2) of section 883(a), (B)income treated as effectively connected with the conduct of a trade or business within the United States under(as in effect before their repeal by the FSC Repeal and Extraterritorial Income Exclusion Act of 2000), (C)gain on the disposition of a United States real property interest described in section 897(c)(1)(A)(ii), (D)income treated as effectively connected with the conduct of a trade or business within the United States under section 953(c)(3)(C), or (E)income treated as effectively connected with the conduct of a trade or business within the United States under section 882(e). (e)

Source

26 USC § 884(d)(2)


Scoping language

For purposes of this section
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