taxable year shall be reduced (but not below zero) by any qualified loss for any prior taxable year beginning on or after the applicable date (as defined in section 300 of the Infrastructure 2.0 Act ), for which the controlled foreign corporation was a controlled foreign corporation, but only to the extent such loss has not been previously taken into account under subsection (b)(2) or this subsection. (3) Qualified loss For purposes of this section— (A) In general The term qualified loss means, with respect to any taxable year, the amount by which the amount determined under paragraph (1)(B) exceeds the amount determined under paragraph (1)(A). (B) Ordering rule for losses carried from prior taxable years In the case of any qualified losses carried to a taxable year from 1 or more prior taxable years, such losses shall be taken into account— (i) first under paragraph (2), and (ii) then under subsection (b)(2)(B) to the extent such losses exceed the amount determined under paragraph (1). (d) Inclusion percentage For purposes of this section— (1) In general The term inclusion percentage means 20 percent increased by the number of percentage points (if any) determined under paragraph (2). (2) Additional inclusion for earnings not subject to OECD average foreign tax The number of percentage points determined under this paragraph with respect to any controlled foreign corporation for any taxable year, is the number of percentage points (not less than zero nor more than 15) which bears the same ratio to 15 as— (A) the number of percentage points by which 25 percent exceeds the aggregate foreign rate of tax imposed on the modified active income of such controlled foreign corporation for such taxable year, bears to (B) 25. (e) Exclusion of United States income For purposes of this subpart, any item of income of the controlled foreign corporation which is effectively connected with the conduct by such corporation of a trade or business within the United States shall not be taken into account in computing the subpart F