Result. (A) Pursuant to § 1.1503(d)– 1(b)(4)(ii), P’s interest in DE1X, and P’s indi- rect ownership of a portion of the Country X operations carried on by PRSZ, are combined and treated as a single separate unit (Coun- try X separate unit). Pursuant to § 1.1503(d)– 5(c)(4)(ii)(A), for purposes of determining P’s items of income, gain, deduction, and loss at- tributable to the Country X separate unit, the items of P are first attributed to each separate unit that composes the Country X separate unit.
Appears in 5 contracts
Samples: www.govinfo.gov, www.govinfo.gov, www.govinfo.gov