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ABC, Inc. is the U . S . Shareholder of one CFC . ABC's pro - rata share of the CFC ' s tested income

ABC, Inc. is the U

.

.

Shareholder of one CFC

.

ABC's pro

-

rata share of the CFC

'

s tested income is $

100, 000

and thier pro

-

rata share of CFC

'

s QBAI is $

500, 000 .

What is ABC'S GILTI inclusion?

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