Result. (A) For purposes of determining the income or dual consolidated loss attrib- utable to P’s Country X separate unit, items of income, gain, deduction, and loss must first be attributed to the individual separate units (that is, P’s interest in DE1X and its in- direct interest in FBX). For purposes of at- tributing items to P’s interest in DE1X, P’s items that are reflected on DE1X’s books and records, as adjusted to conform to U.S. tax principles, are taken into account. See
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