Common use of Result Clause in Contracts

Result. Under § 1.1503(d)–1(b)(4)(i)(B), the partnership interests in HPSX held by P and S are individual hybrid entity separate units. These individual separate units are combined into a single separate unit under § 1.1503(d)–1(b)(4)(ii). In addition, P’s and S’s share of the Country Y operations owned in- directly through their interests in HPSX are individual foreign branch separate units under § 1.1503(d)–1(b)(4)(i)(B). These indi- vidual separate units are also combined into a single separate unit under § 1.1503(d)– 1(b)(4)(ii). Unless an exception under § 1.1503(d)–6 applies, dual consolidated losses attributable to P’s and S’s combined inter- ests in HPSX can only be used to offset in- come attributable to their combined inter- ests in HPSX (other than income attributable to P’s and S’s combined interests in the Country Y foreign branch separate unit), subject to the application of § 1.1503(d)–4(c). Similarly, dual consolidated losses attrib- utable to P’s and S’s combined interests in the Country Y operations of HPSX can only be used to offset income attributable to their combined interests in such Country Y oper- ations, subject to the application of § 1.1503(d)–4(c). Neither FSX’s interest in HPSX, nor its share of the Country Y oper- ations owned by HPSX, is a separate unit be- cause FSX is not a domestic corporation.