accumulated effectively connected earnings and profits
(2) Increase for decrease in net equity (A) In general If— (i) the U.S. net equity of the foreign corporation as of the close of the preceding taxable year, exceeds (ii) the U.S. net equity of the foreign corporation as of the close of the taxable year, the effectively connected earnings and profits for the taxable year shall be increased by the amount of such excess. (B) Limitation (i) In general The increase under subparagraph (A) for any taxable year shall not exceed the accumulated effectively connected earnings and profits as of the close of the preceding taxable year. (ii) Accumulated effectively connected earnings and profits For purposes of clause (i), the term “accumulated effectively connected earnings and profits” means the excess of— (I) the aggregate effectively connected earnings and profits for preceding taxable years beginning after December 31, 1986 , over (II) the aggregate dividend equivalent amounts determined for such preceding taxable years.