Foreign use and indirect foreign use Sample Clauses

Foreign use and indirect foreign use foreign reverse hybrid structure and dis- regarded payments. (i) Facts. P owns DE1X. DE1X owns 99 percent and S owns 1 percent of FRHX, a Country X partnership that elected to be treated as a corporation for U.S. tax purposes. FRHX conducts a trade or business in Country X. In year 1, DE1X incurs interest expense on a third-party loan, which con- stitutes a dual consolidated loss attributable to P’s interest in DE1X. In year 1, for Coun- try X tax purposes, DE1X takes into account its distributive share of income generated by FRHX and offsets such income with its inter- est expense.