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If a CFC distributes in the middle of the year.In yr 1 they had a loss an yr 2 in which the distribution was done

If a CFC distributes in the middle of the year.In yr 1 they had a loss an yr 2 in which the distribution was done mid year they had money inclusive of GILTI. What would this distribution be considered? Either as previously taxed profit or untaxed profit.

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