R Corp Clause Samples

R Corp a foreign railroad, ac- quires new rolling stock and enters into a sale and leaseback transaction with B Corp., a domestic corporation. R uses the rolling stock within and without the United States, but predominantly outside the United States within the meaning of section 48(a)(2)(A). Section 48(a)(2)(B)(ii) is inapplicable to R be- cause R is neither a domestic railroad cor- poration nor a United States person; there- fore, the rolling stock cannot be section 38 property to R. The property is not qualified leased property.