### Question
How is the "nondeductible CFC dividends" defined?


### Answer
The term **nondeductible CFC dividends** is defined in *26 U.S.C. § 965* as follows -

> the excess of the amount of dividends taken into account under subsection (a) over the deduction allowed under subsection (a) for such dividends

#### Citation:
  - *26 U.S.C. § 965*
  - 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 III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart F-Controlled Foreign Corporations**

