### Question
How is the term post-1986 earnings and profits defined?


### Answer
The term **post-1986 earnings and profits** is defined in *26 U.S.C. § 1291* as the following:

> earnings and profits which were accumulated in taxable years of such company beginning after December 31, 1986, and during the period or periods the stock was held by the taxpayer while the company was a passive foreign investment company

#### Citation:
  - *26 U.S.C. § 1291*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter P-Capital Gains and Losses > PART VI-TREATMENT OF CERTAIN PASSIVE FOREIGN INVESTMENT COMPANIES > Subpart A-Interest on Tax Deferral**

