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Study selection: Cross-sectional studies, cohort studies, case series studies, and case series on transmission reporting the number of asymptomatic infections among the tested and confirmed COVID-19 populations that were published in Chinese or English were included.
Results: Ninety-five unique eligible studies were included, covering 29 776 306 individuals undergoing testing. The pooled percentage of asymptomatic infections among the tested population was 0.25% (95% CI, 0.23%-0.27%), which was higher in nursing home residents or staff (4.52% [95% CI, 4.15%-4.89%]), air or cruise travelers (2.02% [95% CI, 1.66%-2.38%]), and pregnant women (2.34% [95% CI, 1.89%-2.78%]). The pooled percentage of asymptomatic infections among the confirmed population was 40.50% (95% CI, 33.50%-47.50%), which was higher in pregnant women (54.11% [95% CI, 39.16%-69.05%]), air or cruise travelers (52.91% [95% CI, 36.08%-69.73%]), and nursing home residents or staff (47.53% [95% CI, 36.36%-58.70%]).
Conclusions and relevance: In this meta-analysis of the percentage of asymptomatic SARS-CoV-2 infections among populations tested for and with confirmed COVID-19, the pooled percentage of asymptomatic infections was 0.25% among the tested population and 40.50% among the confirmed population. The high percentage of asymptomatic infections highlights the potential transmission risk of asymptomatic infections in communities.
The proposed regulations do not address Secs. 250 and 960; forthcoming regulations will do so. The proposed regulations also do not address many of the questions left open under the statute regarding the interplay between the GILTI rules and other Code sections, although some of these questions are raised in the preamble. Treasury notes that taxpayers have raised questions on the application of the dividends-received deduction under Sec. 245A, the anti-hybrid rules of Sec. 267A, and the interest limitation in Sec. 163(j) to the calculation of tested income and tested loss. Rather than resolve these questions in the proposed regulations, Treasury has noted that these items will be addressed in future guidance.
Treasury notes in the preamble that it anticipates issuing proposed regulations assigning the Sec. 78 gross-up attributable to the foreign taxes deemed paid to the GILTI foreign tax credit basket. However, Treasury does not indicate that future guidance will address other foreign tax credit-related issues. For example, the preamble does not indicate whether the lookthrough rule in Sec. 904(d) will apply to GILTI. Neither the preamble nor the proposed regulations address whether withholding taxes on GILTI previously taxed income (PTI) distributions will be included in the GILTI basket and subject to the 20% \"haircut\" in Sec. 960(d). The proposed regulations and preamble are also silent on the treatment of taxes that are \"properly attributable\" to tested income and are paid in a year other than the year in which the tested income is included in the U.S. shareholder's GILTI inclusion amount.
Comments submitted before issuance of the proposed regulations asked Treasury to adopt rules to allow for the carryover of a tested loss, similar to the existing rules for net operating loss carryovers that apply for determining the taxable income of a U.S. corporation. The proposed regulations, however, do not adopt such a rule to allow for the carryover of a tested loss.
Consistent with the definition of tested income under Sec. 951A(c)(2), the proposed regulations exclude from tested income any Subpart F income of a CFC that is excluded from foreign base company income or insurance income solely by reason of the high-tax exception. Accordingly, the proposed regulations do not exclude (or permit an exclusion) from tested income any non-Subpart F income that is subject to a high amount of tax.
Under Sec. 951A and the proposed regulations, a U.S. shareholder's GILTI inclusion amount for a tax year equals the excess (if any) of the U.S. shareholder's \"net CFC tested income\" over its \"net deemed tangible income return.\" Thus formulated, GILTI represents an amount deemed to be \"excessive\" as compared with a specified return.
A U.S. shareholder's net CFC tested income for a tax year equals the excess (if any) of: (1) the U.S. shareholder's aggregate pro rata share of the tested income of each of its CFCs for the tax year over (2) the U.S. shareholder's aggregate pro rata share of the tested loss of each of its CFCs for the tax year.3 (For purposes of Sec. 951A, a U.S. shareholder's pro rata share of a relevant item of a CFC is determined under Sec. 951(a)(2) in the same manner as that section applies to Subpart F income, taken into account in the tax year of the U.S. shareholder (the \"U.S. shareholder inclusion year\" under the proposed regulations) within or with which the tax year of the CFC (the \"CFC inclusion year\" under the proposed regulations) ends.)
By definition, a CFC in a CFC inclusion year can have tested income or a tested loss, but not both. A CFC has tested income for a CFC inclusion year to the extent that: (1) the CFC's gross income for the tax year (\"gross tested income\" under the proposed regulations), excluding items of gross income in certain categories (\"excluded gross income\"), exceeds (2) the deductions (including taxes) properly allocable (under rules similar to those of Sec. 954(b)(5)) to the gross tested income (\"allowable deductions\" under the proposed regulations).4 A CFC with tested income in a CFC inclusion year is a \"tested income CFC\" for that year under the proposed regulations. A CFC has a tested loss for a tax year to the extent that its allowable deductions exceed its gross tested income.5 A CFC with a tested loss in a CFC inclusion year is a \"tested loss CFC\" for that year under the proposed regulations.
Sec. 951A also provides a coordination rule that is intended to deny a double benefit resulting from tested losses. Under that coordination rule, a tested loss CFC increases its earnings and profits (E&P) by the amount of its tested loss for purposes of applying the Subpart F current-year E&P limitation in Sec. 952(c)(1)(A) (the \"tested loss add-back\").7 There is no indication that tested loss must offset tested income to be subject to this rule.
A U.S. shareholder's \"net deemed tangible income return\" for a U.S. shareholder inclusion year equals the excess of: (1) 10% of the U.S. shareholder's aggregate pro rata share of the QBAI of each of its CFCs (for the CFC's inclusion year ending with or within the U.S. shareholder inclusion year) over (2) the amount of interest expense of each of the U.S. shareholder's CFCs that constitutes an allowable deduction in the U.S. shareholder inclusion year, to the extent that the interest income attributable to the expense is not taken into account in determining the U.S. shareholder's net CFC tested income.8 The proposed regulations generally refer to the amount in item (2) as \"specified interest expense.\"
A CFC's QBAI for a tax year means the average of its aggregate adjusted bases (for U.S. federal income tax purposes, as measured as of the close of each quarter of the tax year) in specified tangible property used by the CFC in a trade or business and for which a deduction is allowable under Sec. 167.9 \"Specified tangible property\" generally means any tangible property used in the production of tested income.10 Tangible property used by a CFC in the production of tested income and income that is not tested income is treated as specified tangible property in the same proportion as the tested income produced with respect to the property bears to the total gross income produced with respect to the property. The adjusted basis in any property is determined by using the alternative depreciation system (ADS) under Sec. 168(g) and by allocating the depreciation deduction ratably to each day during the period in the tax year to which the depreciation relates.11
Prop. Regs. Sec. 1.951A-1 provides general rules regarding a U.S. shareholder's GILTI inclusion amount; ensuing sections include specific rules as to the calculation of tested income, tested loss, QBAI, tested interest expense, and tested interest income (each a CFC tested item). This section describes three important rules in Prop. Regs. Sec. 1.951A-1: (1) the relevant date for pro rata share determination; (2) the calculation of a U.S. shareholder's pro rata share of CFC tested items; and (3) the definition of specified interest expense.
Unlike the statute, which calculates tested income and tested loss based on the tax year of the CFC that ends with or within the U.S. shareholder's year, the proposed regulations require inclusion based on the CFC inclusion date, irrespective of the CFC's year end.
Pro rata share rules: Consistent with the statute, the proposed regulations provide rules to determine a U.S. shareholder's pro rata share of each CFC tested item, based on the pro rata share rules of Sec. 951(a) and the regulations thereunder (including amendments under new Prop. Regs. Sec. 1.951-1; the \"Sec. 951(a)(2) rules\"). Prop. Regs. Sec. 1.951A-1, however, modifies the application of the Sec. 951(a)(2) rules to CFC tested items in certain important respects. In general, a U.S. shareholder's pro rata share of each CFC tested item is generally independent of its pro rata share of any other CFC tested item. The amount of a U.S. shareholder's pro rata share of any CFC tested item is translated into U.S. dollars using the average exchange rate for the CFC inclusion year.20
Further, Prop. Regs. Sec. 1.951-1(e) changes the total amount deemed distributed in the hypothetical distribution. Prop. Regs. Sec. 1.951-1(e) determines not only a U.S. shareholder's pro rata share of a CFC's Subpart F income but also its pro rata share of the CFC's tested income and loss. Tested income and loss are taxable income concepts that, unlike Subpart F income, are not limited by current-year E&P. In view of this fact, to permit the hypothetical-distribution rule to operate simultaneously and consistently with respect to Subpart F income (on the one hand) and tested income and loss (on the other), Prop. Regs. Sec. 1.951-1(e) specifies that the amount of the hypothetical distribution is the greater of: (1) the CFC's current-year E&P (determined under Sec. 964) and (2) the sum of the Subpart F income (increased by reason of any tested loss add-back) and the CFC's tested income for the year.21 153554b96e
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