Page 737 - Large Business IRS Training Guides

E&P Categories

section 959, E&P is classified into three categories –
• Under

1) 959(c)(1): Includes E&P attributable to section 956 inclusions

2) 959(c)(2): Includes E&P attributable to subpart F income (and

now GILTI)

All other E&P (generally previously untaxed E&P)
3) 959(c)(3):

“E&P” during this presentation, we are
• When we’ve talked about

three of these categories.
referring to the sum of all

• Section 959(c)(1)
and 959(c)(2) E&P is E&P that has previously
been subject
to U.S. taxation, and is fittingly referred to as:

• Previously
taxed earnings and profits (PTEP), or

taxed income (PTI).
• Previously

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