(1) In this section -
'applicable rate' means the rate at which foreign taxes on controlled foreign company income generally fully offset the controlled foreign company tax through the tax credit mechanism applicable to the controlled foreign company tax regime;
'attributable income of the entity' means the constituent entity-owner's proportionate share of the income of the constituent entity in the jurisdiction in which the constituent entity is located as determined under the blended CFC tax regime;
'blended CFC tax regime' means a controlled foreign company tax regime that aggregates -
(a) income,
(b) losses, and
(c) creditable taxes,
of all the controlled foreign companies of a constituent entity-owner for the purposes of calculating the constituent entity-owner's tax liability under the regime and that has an applicable tax rate of less than 15 per cent, but does not include a regime that takes into account income other than income of the controlled foreign companies except that
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