domestic loss

(B)For purposes of subparagraph (A), the term “domestic loss” means the amount by which the gross income for the taxable year from sources within the United States is exceeded by the sum of the deductions properly apportioned or allocated thereto (determined without regard to any carryback from a subsequent taxable year).


26 USC § 904(g)(2)(B)

Scoping language

For purposes of subparagraph
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