...limitations determined under (a) and (b) of this subdivision: fa} Such shareholder's pro rata share of trie sum of the controlled foreign corporation's earnings...distributions made du-ring the taxable year, plus his pro rstta share of the sum of its earnings and profits (or deficits in earnings and profits) accumulated...

...controlled foreign corporation shall be the lesser of the following two limitations: (A) The sum of (1) the controlled foreign corporation's earnings and...the taxable year without diminution by reason of any distribution made during the taxable year, (2) the sum of its earnings and profits (or deficits in...

...limitations determined under (a) and (b) of this subdivision: (a) Such shareholder's pro rata share of the sum of the controlled foreign corporation's earnings...of the close of the taxable year without diminution bj reason of any distributions made durini the taxable year, plus his pro rata shart of the sum of...

...percent of its gross income from sources within the United States. A's earnings and profits for 1963 (computed as of the close of the taxable year without...of any distributions made during the taxable year) are $200,000. On December 31, 1963, corporation A distributes to corporation B 100 shares of corporation...

...percent of its gross income from sources within the United States. A's earnings and profits for 1963 (computed as of the close of the taxable year without...of any distributions made during the taxable year) are $200,000. On December 31, 1963, corporation A distributes to corporation B 100 shares of corporation...

...during such year X received tax-exempt interest of $500. X's earnings and profits for 1963 (computed at the close of the taxable year without diminution by...of any distributions made during the taxable year) is $20,400. The opening balance of X's reserve for losses on qualifying real property loans as of the...

...controlled foreign corporation's earnings and profits (or deficit in earnings and profits) for §1.955A-1 the taxable year, computed as of the close of the taxable year without diminution by reason of any distribution made during the taxable year, (2) the sum of its earnings and profits (or deficits in...

...percent of its gross Income from sources within the United States. A's earnings and profits for 1963 (computed as of the close of the taxable year without diminution by reason of any distributions made daring the taxable year) are $200,000. On December 31, 1963, corporation A distributes to corporation...

...its earnings or profits accumulated after February 28, 1913, or (2) out of the earnings or profits of the taxable year (Computed as of the close of the...of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made. Such...

...its earnings or profits accumulated after February %8, 1913, or (2) out of the earnings or profits of the taxable year (Computed as of the close of the...of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made. Such...