Subchapter C earnings and profits. For purposes of this paragraph (c), sub- chapter C earnings and profits of a cor- poration are the earnings and profits of any corporation, including the S cor- poration or an acquired or predecessor corporation, for any period with re- spect to which an election under sec- tion 1362(a) (or under section 1372 of prior law) was not in effect. The sub- chapter C earnings and profits of an S corporation are modified as required by section 1371(c).
Subchapter C earnings and profits. IPT does not have any earnings and profits in excess of $1 million accumulated in any non-REIT year within the meaning of Section 857 of the Code, including as a result of the AMIT Merger.
