gross tested income
(3) Gross tested income. The term gross tested income has the meaning provided in 1.951A-2(c)(1). (4) Inclusion percentage. The term inclusion percentage has the meaning provided in 1.960-2(c)(2). (5) Separate category. The term separate category has the meaning provided in 1.904-5(a)(4)(v). (6) Treaty category. The term treaty category means a category of income earned by a controlled foreign corporation for which section 904(a), (b), and (c) are applied separately as a result of income being resourced under a treaty. See, for example, section 245(a)(10), 865(h), or 904(h)(10). A United States shareholder may have multiple treaty categories for amounts of income resourced by the United States shareholder under a treaty. See 1.904-5(m)(7). (7) U.S. source category. The term U.S. source category means the aggregate of U.S. source income in each separate category listed in section 904(d)(1).