26 U.S.C. § 532: Corporations subject to accumulated earnings tax

The accumulated earnings tax imposed by section 531 shall apply to every corporation (other than those described in subsection (b)) formed or availed of for the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate instead of being divided or distributed. a personal holding company (as defined in section 542), a corporation exempt from tax under subchapter F (section 501 and following), or a passive foreign investment company (as defined in section 1297). The application of this part to a corporation shall be determined without regard to the number of shareholders of such corporation. taxable years of United States persons beginning after December 31, 1997 , and taxable years of foreign corporations ending with or within such taxable years of United States persons.”