### Question
What does effectively connected earnings and profits mean?


### Answer
**Effectively connected earnings and profits** has the following meaning in *26 U.S.C. § 884*:

> earnings and profits (without diminution by reason of any distributions made during the taxable year) which are attributable to income which is effectively connected (or treated as effectively connected) with the conduct of a trade or business within the United States

#### Citation:
  - *26 U.S.C. § 884*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART II-NONRESIDENT ALIENS AND FOREIGN CORPORATIONS > Subpart B-Foreign Corporations**

