### Question
Can you define what undistributed foreign earnings means?


### Answer
**Undistributed foreign earnings** is defined as the following in *26 U.S.C. § 245A*:

> the portion of the undistributed earnings which is attributable to neither—


(A) income described in subparagraph (A) of section 245(a)(5), nor


(B) dividends described in subparagraph (B) of such section (determined without regard to section 245(a)(12))

#### Citation:
  - *26 U.S.C. § 245A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter B-Computation of Taxable Income > PART VIII-SPECIAL DEDUCTIONS FOR CORPORATIONS**

