I.R.C. § 959 – Previously Taxed Earnings and Profits (PTEP)
The term PTEP refers to earnings and profits (E&P) of a foreign corporation attributable to amounts which are, or have been, included in the gross income of a U.S. shareholder under Sec. 951(a) or under Sec. 1248(a). Sec. 959(a)(1): Distributions