(2) Qualifying dividends (A) In general Except as provided in regulations, the term “extraordinary dividend” does not include any qualifying dividend (within the meaning of section 243 ). (B) Exception Subparagraph (A) shall not apply to any portion of a dividend which is attributable to earnings and profits which— (i) were earned by a corporation during a period it was not a member of the affiliated group, or (ii) are attributable to gain on property which accrued during a period the corporation holding the property was not a member of the affiliated group.
26 USC § 1059(e)(2)
None identified. Default scope is assumed to be the entire title.