Page 43 - Large Business IRS Training Guides

BE%
– The Denominator

• The denominator of
BE%, as discussed above, is the

and BETBs that are not
sum of allowable deductions

deductions

• Total deductions in the denominator do not include –

under section 172
• net operating losses (NOL)

• deduction for
foreign source portion of dividends received

specified 10 percent owned foreign corporations
from
(section 245A)

foreign-derived intangible income and global
• deduction for
intangible low-taxed income (section 250)

• exchange losses
from section 988 transactions

• deduction not allowed in determining taxable income for

the taxable year

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