In terms of the new Subpart F category of income for GILTI, which comments is not agreeable?

$($a$)$ GILTI is$,$ with respect to any U$.$S$.$ shareholder for any taxable year of the U$.$S$.$ shaareholder, theexcess $($if any$)$ of the shareholder's net CFC tested income for such taxable year, over the sharholder's net deemed tangible income return for such taxable year

$($b$)$ Like Subpart F gross income inclusions for other categories, there is no offset for the gross income inclusion

$($c$)$ As a reult of the TCJA, subpart F has been expanded and now requires a person who is a U$.$S$.$ shareholder of any CFC to include its global intangible low$-$taxed income $($GILTI$)$ in gross income for the tax year in a manner generally similar to that for other Subpart F inclusions.

$($d$)$ Generally, the Subpart F income of any CFC for any taxable year cannot exceed the earnings and profits of such corporation for such taxable year. Where there is a tested loss under the GILTII provision, the earnings and profits of the CFC is increased by the tested loss of such corporation