High-taxed income's any income (tested after allocation of expenses) that would otherwise be passive income but isn't treated as such because the sum of foreign income taxes paid and deemed paid with respect to that income exceeds the tentative U.S. income tax liability with respect to that income. This exclusion ensures the separate limitation for passive income segregates low-taxed, passive income from high-taxed, passive income, avoiding substantial averaging within the passive basket. Through
Passive Source Grouping
, you instruct the system to group income items together to treat them as 1 unit to determine if such items, as grouped, are high-taxed income.