Common use of Result Clause in Contracts

Result. Under § 1.1503(d)–1(b)(4)(i)(A), P’s and S’s shares of FBX owned indirectly through their interests in PRSX are indi- vidual foreign branch separate units. Pursu- ant to § 1.1503(b)–1(b)(4)(ii), these individual separate units are combined and treated as a single separate unit of the consolidated group of which P is the parent. Unless an ex- ception under § 1.1503(d)–6 applies, any dual consolidated loss attributable to FBX cannot offset income of P or S (other than income attributable to FBX, subject to the applica- tion of § 1.1503(d)–4(c)), including their dis- tributive share of the U.S. source income earned through their interests in PRSX, nor can it offset income of any other domestic affiliates.