; tested loss For purposes of this section— (A) Tested income The term tested income means, with respect to any controlled foreign corporation for any taxable year of such controlled foreign corporation, the excess (if any) of— (i) the gross income of such corporation determined without regard to— (I) any item of income which is effectively connected with the conduct by such corporation of a trade or business within the United States if subject to tax under this chapter, (II) any gross income taken into account in determining the subpart F income of such corporation, (III) except as otherwise provided by the Secretary, any amount excluded from the foreign personal holding company income (as defined in section 954) of such corporation by reason of section 954(c)(6) but only to the extent that any deduction allowable for the payment or accrual of such amount does not result in a reduction in the foreign high return amount of any United States shareholder (determined without regard to this subclause), (IV) any gross income excluded from the foreign personal holding company income (as defined in section 954) of such corporation by reason of subsection (c)(2)(C), (h), or (i) of section 954, (V) any gross income excluded from the insurance income (as defined in section 953) of such corporation by reason of section 953(a)(2), (VI) any gross income excluded from foreign base company income (as defined in section 954) or insurance income (as defined in section 953) of such corporation by reason of section 954(b)(4), (VII) any dividend received from a related person (as defined in section 954(d)(3)), and (VIII) any commodities gross income of such corporation, over (ii) the deductions (including taxes) properly allocable to such gross income under rules similar to the rules of section 954(b)(5) (or which would be so properly allocable if such corporation had such gross income). (B) Tested loss The term tested loss means, with respect to any controlled foreign corporation for any taxable year of such controlled foreign