(1) The covered taxes of a constituent entity shall include -
(a) taxes recorded in the financial accounts of a constituent entity with respect to its income or profits, or its share of the income or profits of a constituent entity in which it owns an ownership interest,
(b) taxes on distributed profits, deemed profit distributions, and non-business expenses imposed under an eligible distribution tax system,
(c) taxes imposed in lieu of a generally applicable corporate income tax, and
(d) taxes levied by reference to retained earnings and corporate equity, including taxes on multiple components based on income and equity.
(2) The covered taxes of a constituent entity shall not include -
(a) the top-up tax accrued by a parent entity under a qualified IIR,
(b) the top-up tax accrued by a constituent entity under a qualified domestic top-up tax,
(c) taxes attributable to an adjustment made by a constituent entity as a result of the application of a qualified UTPR,
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