deduction eligible income
(3) Deduction eligible income (A) In general The term “deduction eligible income” means, with respect to any domestic corporation, the excess (if any) of— (i) gross income of such corporation determined without regard to— (I) any amount included in the gross income of such corporation under section 951(a)(1), (II) the global intangible low-taxed income included in the gross income of such corporation under section 951A, (III) any financial services income (as defined in section 904(d)(2)(D)) of such corporation, (IV) any dividend received from a corporation which is a controlled foreign corporation of such domestic corporation, (V) any domestic oil and gas extraction income of such corporation, and (VI) any foreign branch income (as defined in section 904(d)(2)(J) ), over (ii) the deductions (including taxes) properly allocable to such gross income. (B) Domestic oil and gas extraction income For purposes of subparagraph (A), the term “domestic oil and gas extraction income” means income described in section 907(c)(1), determined by substituting “within the United States” for “without the United States”.