US Codex
U.S.C.
Notes

§964. Miscellaneous provisions — Inbound Citations

26 U.S.C. § 964

Cited by 5 provisions in release 119-102.

Citations to §964(a)

  • 26 U.S.C. § 245(a)(4)
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    (4) 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.
  • 26 U.S.C. § 245A(c)(2)
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    (2) The term “undistributed earnings” means the amount of the earnings and profits of the specified 10-percent owned foreign corporation (computed in accordance with sections 964(a) and 986)—
    (A) as of the close of the taxable year of the specified 10-percent owned foreign corporation in which the dividend is distributed, and
    (B) without diminution by reason of dividends distributed during such taxable year.
  • 26 U.S.C. § 909(b)(2)
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    (2) for purposes of determining earnings and profits under section 964(a),
  • 26 U.S.C. § 965(d)(3)
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    (3) The term “post-1986 earnings and profits” means the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986, and by only taking into account periods when the foreign corporation was a specified foreign corporation) accumulated in taxable years beginning after December 31, 1986, and determined—
    (A) as of the date referred to in paragraph (1) or (2) of subsection (a), whichever is applicable with respect to such foreign corporation, and
    (B) without diminution by reason of dividends distributed during the taxable year described in subsection (a) other than dividends distributed to another specified foreign corporation.

Citations to §964(e)(4)