allocable share
(3) Allocable share. The term allocable share means, with respect to a member that is a United States shareholder and a U.S. shareholder inclusion year (i) With respect to consolidated QBAI, the product of the consolidated QBAI of the member's consolidated group and the member's GILTI allocation ratio. (ii) With respect to consolidated specified interest expense, the product of the consolidated specified interest expense of the member's consolidated group and the member's GILTI allocation ratio. (iii) With respect to consolidated tested loss, the product of the consolidated tested loss of the member's consolidated group and the member's GILTI allocation ratio. (4) Consolidated QBAI. With respect to a consolidated group, the term consolidated QBAI means the sum of each member's pro rata share (determined under 1.951A-1(d)(3)) of the qualified business asset investment of each tested income CFC for a CFC inclusion year that ends with or within the U.S. shareholder inclusion year. (5) Consolidated specified interest expense. With respect to a consolidated group, the term consolidated specified interest expense means the excess (if any) of (i) The sum of each member's pro rata share (determined under 1.951A-1(d)(5)) of the tested interest expense of each controlled foreign corporation for a CFC inclusion year that ends with or within the U.S. shareholder inclusion year, over (ii) The sum of each member's pro rata share (determined under 1.951A-1(d)(6)) of the tested interest income of each controlled foreign corporation for a CFC inclusion year that ends with or within the U.S. shareholder inclusion year. (6) Consolidated tested income. With respect to a consolidated group, the term consolidated tested income means the sum of each member's aggregate tested income for the U.S. shareholder inclusion year. (7) Consolidated tested loss. With respect to a consolidated group, the term consolidated tested loss means the sum of each member's aggregate tested loss for the U.S. shareholder inclusion year. (8) Controlled foreign corporation. The term controlled foreign corporation has the meaning provided in 1.951A-1(f)(2). (9) Deemed tangible income return. With respect to a member, the term deemed tangible income return means 10 percent of the member's allocable share of the consolidated QBAI. (10) GILTI allocation ratio. With respect to a member, the term GILTI allocation ratio means the ratio of (i) The aggregate tested income of the member for the U.S. shareholder inclusion year, to (ii) The consolidated tested income of the consolidated group of which the member is a member for the U.S. shareholder inclusion year. (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).