Assume in $2023,$ a domestic corporation P$,$ a C corporation, directly owns two CFCs$,$ CFC $1$ and CFC $2.$ Assume CFC $1$ has $$700$ million in tested income, with a Qualified Business Asset Investment $($QBAI$)$ of $$150$ million. CFC $2$ has a tested loss of $$300$ million and QBAI for that year of $$90$ million. Assume there

are no potential foreign tax credits available from CFC $1$ and CFC $2.$ Also assume there is no interest expense incurred by CFC $1$ and CFC $2.$ Please calculate the federal income of P resulting from the GILTI provision in $2023.$