tested income
(A)The term “tested income” means, with respect to any controlled foreign corporation for any taxable year of such controlled foreign corporation, the excess (if any) of— (i)the gross income of such corporation determined without regard to— (I)any item of income described in section 952(b), (II)any gross income taken into account in determining the subpart F income of such corporation, (III)any gross income excluded from the foreign base company income (as defined in section 954) and the insurance income (as defined in section 953) of such corporation by reason of section 954(b)(4), (IV)any dividend received from a related person (as defined in), and (V)any foreign oil and gas extraction income (as defined in section 907(c)(1)) of such corporation, over (ii)the deductions (including taxes) properly allocable to such gross income under rules similar to the rules of(or to which such deductions would be allocable if there were such gross income). (B)