Page 655 - Large Business IRS Training Guides
P. 655
Step 2
Step 2: Calculate the US shareholder’s net
deemed tangible income return
* CFC4 is a tested loss CFC, so its QBAI is zero.
**If CFC4 were not a tested loss CFC, its QBAI would be 800x, so its
tested interest expense of 100x is reduced by 80x (i.e. 10% of 800x).
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