CFC is owned 100% by a US shareholder. The CFC had many years of losses such that the Retained Earnings or the Accumulated E&P has deficits until 2018. In 2019 and 2020 the CFC has substantial income but the Accum E&P or RE is still a deficit through 2020. Does the shareholder have GILTI income for 2019 and 2020 due to the net income of the CFC in those years.