Document ID: chunk:federal_register_of_legislation:F2024L01740:reg:10:p3
Version: federal_register_of_legislation:F2024L01740
Segment Type: reg
Provision Reference: reg 10 (pt 3/10)
Character Range: 356230–359239

to current taxation on its share of part or all of the income earned by the CFC, irrespective of whether that income is distributed currently to the owner.
Cooperative means an Entity that:
 (a) collectively markets or acquires goods or services on behalf of its members; and
 (b) is subject to a tax regime in the jurisdiction in which it is located that is designed to ensure tax neutrality in respect of:
 (i) members' property or services sold through the cooperative; and
 (ii) property or services acquired by members through the cooperative.
Country‑by‑Country Reporting regulations: see subsection 8‑195(2).
Covered Taxes: see section 4‑40.
Deductible Dividend: see section 7‑35.
Deductible Dividend Regime: see section 7‑30.
deduction/non‑inclusion arrangement: see section 8‑120.
Deemed Distribution Tax Recapture Account: see subsection 7‑50(3).
De minimis test: see section 8‑20.
Disallowed Accrual: see subsection 4‑115(1).
Disposition Recapture Ratio: see subsection 7‑75(3).
Disqualified Refundable Imputation Tax means an amount of Tax, other than a Qualified Imputation Tax, accrued or paid by a Constituent Entity that is:
 (a) refundable to the beneficial owner of a dividend distributed by the Constituent Entity in respect of the dividend or creditable by the beneficial owner against a tax liability other than a tax liability in respect of such dividend; or
 (b) refundable to the distributing corporation upon distribution of a dividend.
Domestic Top‑up Tax Amount: see sections 2‑25 and 2‑30.
Dual‑listed Arrangement: see subsection 6‑85(4).
duplicate loss arrangement: see section 8‑125.
duplicate tax recognition arrangement: see section 8‑130.
Effective Tax Rate: see section 5‑5.
Eligible Distribution Tax System: see section 7‑45.
Eligible Employee: see subsection 5‑60(2).
Eligible Payroll Costs: see subsection 5‑60(1).
Eligible Tangible Asset: see section 5‑75.
ETR Adjustment Provision: see subsection 5‑95(6).
Excess Negative Tax Expense Carry‑forward: see subparagraphs 4‑35(3)(a)(i) and 5‑10(3)(a)(i).
Excess Profit: see section 5‑25.
Excluded Dividends: see subsections 3‑25(1) and (2).
Excluded Equity Gain or Loss: see subsection 3‑35(1).
Excluded Exempt Income Entity: see subsection 1‑20(2).
Excluded Non‑Profit Subsidiary: see subsection 1‑20(3).
Financial Accounting Net Income or Loss: see sections 3‑10 and 3‑240.
Flow‑through Entity: see section 10‑30.
GloBE Implementation Framework: see section 10‑10.
GloBE Income: if the GloBE Income or Loss of a Constituent Entity of an MNE Group for a Fiscal Year is a positive amount, the Constituent Entity's GloBE Income for the Fiscal Year is that amount.
GloBE Income or Loss: see section 3‑5.
Note: The GloBE Income or Loss could be a positive or negative amount.
GloBE Loss: if the GloBE Income or Loss of a Constituent Entity of an MNE Group for a Fiscal Year is a negative amount, the Constituent Entity's GloBE Loss for the Fiscal Year is the absolute value of that amount.
GloBE Loss Deferred Tax Asset:
 (a) of