Common use of Result Clause in Contracts

Result. Under § 1.1503(d)–3(c)(3), DRCX’s $200x loss shall be treated as having been made available to offset the $200x of income attributable to P’s Country X separate unit. P’s Country X separate unit is not, under U.S. tax principles, a foreign corporation, and there is no interest in DE1X (which is a hybrid entity) that is not a separate unit. As a result, DRCX’s loss being made available to offset the income attributable to P’s Coun- try X separate unit is not considered a for- eign use of such loss. Therefore, P can make a domestic use election with respect to DRCX’s year 1 dual consolidated loss.