Dividends
(A) In general
(A)In general#
The United States source ratio of any dividend paid or accrued by a United States-owned foreign corporation shall be treated as derived from sources within the United States.
(B)United States source ratio#
For purposes of subparagraph (A), the term “United States source ratio” means, with respect to any dividend paid out of the earnings and profits for any taxable year, a fraction—
(i) the numerator of which is the portion of the earnings and profits for such taxable year from sources within the United States, and
(ii) the denominator of which is the total amount of earnings and profits for such taxable year.
(B)(i)#
the numerator of which is the portion of the earnings and profits for such taxable year from sources within the United States, and
(B)(ii)#
the denominator of which is the total amount of earnings and profits for such taxable year.