### Question
How does INCOME FROM SOURCES WITHOUT THE UNITED STATES define nondeductible CFC dividends?


### Answer
Under *26 U.S.C. § 965*, **nondeductible CFC dividends** is defined as:

> 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**

