income means, with respect to any controlled foreign corporation, the excess (if any) of— (A) the corporation's active foreign market income, over (B) the amount of the reduction under subsection (e) for deductions properly allocable to such income. (2) Reduction for certain losses (A) In general The modified active income determined under paragraph (1) for any taxable year shall be reduced (but not below zero)— (i) first by any active foreign market loss for any prior taxable year, and (ii) then by any qualified loss for such taxable year (or for any prior taxable year to the extent provided in subsection (c)(3)(B)). (B) Limitation An active foreign market loss or qualified loss for any prior taxable year shall only be taken into account under subparagraph (A)— (i) if the prior taxable year is a taxable year which begins on or after the applicable date (as defined in section 300 of the Infrastructure 2.0 Act ), and for which the controlled foreign corporation was a controlled foreign corporation, and (ii) to the extent such loss has not been previously taken into account under this subsection. (3) Active foreign market loss The term active foreign market 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). (c) Modified nonactive income (1) In general The term modified nonactive income means, with respect to any controlled foreign corporation, the excess (if any) of— (A) the corporation's gross income determined without regard to active foreign market income, over (B) the amount of the reduction under subsection (e) for deductions properly allocable to such gross income. (2) Reduction for qualified losses The amount determined under paragraph (1) for any 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