GILTI inclusion amount
(11) GILTI inclusion amount. With respect to a member, the term GILTI inclusion amount has the meaning provided in paragraph (b) of this section. (12) Net CFC tested income. With respect to a member, the term net CFC tested income means the excess (if any) of (i) The member's aggregate tested income, over (ii) The member's allocable share of the consolidated tested loss. (13) Net deemed tangible income return. With respect to a member, the term net deemed tangible income return means the excess (if any) of the member's deemed tangible income return over the member's allocable share of the consolidated specified interest expense. (14) through (16) [Reserved] (17) Qualified business asset investment. The term qualified business asset investment has the meaning provided in 1.951A-3(b). (18) Tested income. The term tested income has the meaning provided in 1.951A-2(b)(1). (19) Tested income CFC. The term tested income CFC has the meaning provided in 1.951A-2(b)(1). (20) Tested interest expense. The term tested interest expense has the meaning provided in 1.951A-4(b)(1). (21) Tested interest income. The term tested interest income has the meaning provided in 1.951A-4(b)(2). (22) Tested loss. The term tested loss has the meaning provided in 1.951A-2(b)(2). (23) Tested loss CFC. The term tested loss CFC has the meaning provided in 1.951A-2(b)(2). (24) United States shareholder. The term United States shareholder has the meaning provided in 1.951A-1(f)(6). (25) U.S. shareholder inclusion year. The term U.S. shareholder inclusion year has the meaning provided in 1.951A-1(f)(7).