deemed tangible income return
(2) Deemed intangible income For purposes of this subsection— (A) In general The term “deemed intangible income” means the excess (if any) of— (i) the deduction eligible income of the domestic corporation, over (ii) the deemed tangible income return of the corporation. (B) Deemed tangible income return The term “deemed tangible income return” means, with respect to any corporation, an amount equal to 10 percent of the corporation’s qualified business asset investment (as defined in section 951A(d), determined by substituting “deduction eligible income” for “tested income” in paragraph (2) thereof and without regard to whether the corporation is a controlled foreign corporation).