Atticus Technologies, Inc. (Atticus US), a corporation organized in the U.S., owns 100% of the stock of Atticus SAS (France), Atticus Plc (Ireland) and Atticus Ltd. (China). Atticus US filed an Entity Classification Election, effective 12/31/2018, to treat Atticus SAS as a disregarded entity for all U.S. tax purposes. For 2019, Atticus SAS generated pre-tax book income of $750,000 and incurred France taxes of $210,000 (28% tax rate), Atticus Plc generated net income of $1,056,000 (12% tax rate) and Atticus Ltd. generated net income of $225,000 (25% tax rate). Assuming $-0- cash distributions in 2019 from the foreign subsidiaries to Atticus US and Atticus US does not assert indefinite reinvestment for Ireland and China unremitted earnings, which of the following represents a Permanent Difference in the Atticus US federal Current Income Tax provision for 2019 (multiple correct answers)?

a. $100,000 of Atticus SAS overhead costs capitalized to inventory under Sec. 263A

b. Sec. 951A tested income of $1,281,000

c. Sec 78 gross-up of $219,000

d. U.S. income tax, if any, U.S. state income tax and Sec. 986(c) Fx gain/(loss) on the 2019 increase in the outside basis for Atticus Plc (Ireland) and Atticus Ltd. (China)

e. Sec. 250 GILTI deduction of $750,000