low-taxed income means, with respect to any United States shareholder for any taxable year of such United States shareholder, the excess (if any) of— (A) such shareholder’s net CFC tested income for such taxable year, over (B) such shareholder's net deemed tangible income return for such taxable year. (2) Net deemed tangible income return The term net deemed tangible income return means, with respect to any United States shareholder for any taxable year, an amount equal to 10 percent of the aggregate of such shareholder’s pro rata share of the qualified business asset investment of each controlled foreign corporation with respect to which such shareholder is a United States shareholder for such taxable year (determined for each taxable year of each such controlled foreign corporation which ends in or with such taxable year of such United States shareholder). (c) Net CFC tested income For purposes of this section— (1) In general The term net CFC tested income means, with respect to any United States shareholder for any taxable year of such United States shareholder, the excess (if any) of— (A) the aggregate of such shareholder’s pro rata share of the tested income of each controlled foreign corporation with respect to which such shareholder is a United States shareholder for such taxable year of such United States shareholder (determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder), over (B) the aggregate of such shareholder’s pro rata share of the tested loss of each controlled foreign corporation with respect to which such shareholder is a United States shareholder for such taxable year of such United States shareholder (determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder). (2) Tested income