inclusion percentage

(2) Inclusion percentage For purposes of paragraph (1), the term “inclusion percentage” means, with respect to any domestic corporation, the ratio (expressed as a percentage) of— (A) such corporation’s global intangible low-taxed income (as defined in section 951A(b) ), divided by (B) the aggregate amount described in section 951A(c)(1)(A) with respect to such corporation.

Source

26 USC § 960(d)(2)

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Scoping language

None identified, default scope is assumed to be the parent (subpart F) of this section.

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