undistributed PFIC earnings tax liability
(1) Undistributed PFIC earnings tax liability The term “undistributed PFIC earnings tax liability” means, in the case of any taxpayer, the excess of— (A) the tax imposed by this chapter for the taxable year, over (B) the tax which would be imposed by this chapter for such year without regard to the inclusion in gross income under section 1293 of the undistributed earnings of a qualified electing fund.