(3) Deferred DISC income For purposes of this subsection— (A) In general The term “deferred DISC income” means, with respect to any taxable year of a shareholder, the excess of— (i) the shareholder’s pro rata share of accumulated DISC income (for periods after 1984) of the DISC as of the close of the computation year, over (ii) the amount of the distributions-in-excess-of-income for the taxable year of the DISC following the computation year. (B) Computation year For purposes of applying subparagraph (A) with respect to any taxable year of a shareholder, the computation year is the taxable year of the DISC which ends with (or within) the taxable year of the shareholder which precedes the taxable year of the shareholder for which the amount of deferred DISC income is being determined. (C) Distributions-in-excess-of-income For purposes of subparagraph (A), the term “distributions-in-excess-of-income” means, with respect to any taxable year of a DISC, the excess (if any) of— (i) the amount of actual distributions to the shareholder out of accumulated DISC income, over (ii) the shareholder’s pro rata share of the DISC income for such taxable year.
26 USC § 995(f)(3)
None identified. Default scope is assumed to be the entire title.