post-1986 undistributed earnings

(4) Post-1986 undistributed earnings The term “post-1986 undistributed earnings” means the amount of the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986 ) accumulated in taxable years beginning after December 31, 1986 — (A) as of the close of the taxable year of the foreign corporation in which the dividend is distributed, and (B) without diminution by reason of dividends distributed during such taxable year.

Source

26 USC § 245(a)(4)

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Scoping language

None identified, default scope is assumed to be the parent (part VIII) of this section.

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