Page 704 - Large Business IRS Training Guides

Accumulated Post-1986 Deferred Foreign Income

& Post-1986 Earnings
and Profits

• Post-1986 Earnings and Profits (“Post-1986 E&P”)

• An SFC’s
post-1986 E&P is E&P accumulated in taxable
12/31/86, but only taking into
years beginning after

account
periods in which the foreign corporation was an
dividends
SFC and without diminution by reason of
distributed during the inclusion year
other than dividends
distributed to another
SFC.

• Accumulated
Post-1986 Deferred Foreign Income

(“DFI”)

the post-1986 earnings and profits of an
• DFI includes
SFC
except generally to the extent the earnings and

connected income (“ECI”) or
profits constitute effectively
previously
taxed income (“PTI”).

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