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DomCo operates abroad through a wholly owned foreign subsidiary, ForCo. ForCo's net tested income is $100,000,000, its average adjusted basis in tangible assets is $30,000,000

DomCo operates abroad through a wholly owned foreign subsidiary, ForCo. ForCo's net tested income is $100,000,000, its average adjusted basis in tangible assets is $30,000,000 and its average adjusted basis in intangible assets is $80,000,000. The foreign tax rate is 0%. 


How much is DomCo's GILTI inclusion in the current year?

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