- 24 - which such taxable year of the corporation ends-- (A) the sum of-- (i) his pro rata share (determined under paragraph (2)) of the corporation’s subpart F income for such year, (ii) his pro rata share (determined under section 955(a)(3) as in effect before the enactment of the Tax Reduction Act of 1975) of the corporation’s previously excluded subpart F income withdrawn from investment in less developed countries for such year, and (iii) his pro rata share (determined under section 955(a)(3)) of the corporation’s previously excluded subpart F income withdrawn from foreign base company shipping operations for such year; and (B) his pro rata share (determined under section 956(a)(2)) of the corporation’s increase in earnings invested in United States property for such year (but only to the extent not excluded from gross income under section 959(a)(2)). (2) Pro rata share of subpart F income.-- The pro rata share referred to in paragraph (1)(A)(i) in the case of any United States shareholder is the amount--Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011