### Question
What is the definition of applicable percentage?


### Answer
The definition of **applicable percentage** is as follows in *26 U.S.C. § 965*:

> the amount (expressed as a percentage) equal to the sum of—


(A) 0.771 multiplied by the ratio of—


(i) the excess to which subsection (c)(1)(A) applies, divided by


(ii) the sum of such excess plus the amount to which subsection (c)(1)(B) applies, plus


  

(B) 0.557 multiplied by the ratio of—


(i) the amount to which subsection (c)(1)(B) applies, divided by


(ii) the sum described in subparagraph (A)(ii)

#### 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**

