Subpart F income
(30) Subpart F income. The term subpart F income has the meaning set forth in section 952 and 1.952-1(a). (31) Subpart F income group. The term subpart F income group has the meaning set forth in paragraph (d)(2)(ii)(B)(1) of this section. (32) Tested foreign income taxes. The term tested foreign income taxes has the meaning set forth in 1.960-2(c)(3). (33) Tested income. The term tested income means the amount with respect to a controlled foreign corporation that is described in section 951A(c)(2)(A) and 1.951A-2(b)(1). (34) Tested income group. The term tested income group has the meaning set forth in paragraph (d)(2)(ii)(C) of this section. (35) United States shareholder. The term United States shareholder has the meaning set forth in section 951(b). (36) U.S. shareholder partner. The term U.S. shareholder partner means, with respect to a U.S. shareholder partnership and a partnership CFC of the U.S. shareholder partnership, a United States person that is a partner in the U.S. shareholder partnership and that is also a United States shareholder (as defined in section 951(b)) of the partnership CFC. (37) U.S. shareholder partnership. The term U.S. shareholder partnership means a domestic partnership (within the meaning of section 7701(a)(4)) that is a United States shareholder of one or more controlled foreign corporations. (38) U.S. taxable year. The term U.S. taxable year has the same meaning as that of the term taxable year set forth in section 7701(a)(23).