Common use of Result Clause in Contracts

Result. There is no recapture of the year 1 dual consolidated loss attributable to P’s Country X separate unit because it is re- duced to zero under § 1.1503(d)–6(h)(2)(i). How- ever, P is liable for one year of interest charge under § 1.1503(d)–6(h)(1)(ii), even though P’s recapture amount is zero. This is the case because the P consolidated group had the benefit of the dual consolidated loss in year 1, and the income that offset the re- capture income was not recognized until year 2. Pursuant to § 1.1503(d)–6(j)(1)(iii), the domestic use agreement filed by the P con- solidated group with respect to the year 1 dual consolidated loss is terminated and has no further effect.