### Question
What does E&P net surplus shareholder mean?


### Answer
**E&P net surplus shareholder** has the following meaning in *26 U.S.C. § 965*:

> any United States shareholder which would (determined without regard to this paragraph) take into account an amount greater than zero under section 951(a)(1) by reason of subsection (a)

#### 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**

