Common use of Result Clause in Contracts

Result. In year 2, under the laws of Country X, the $100x of year 1 loss, which in- cludes the $80x dual consolidated loss attrib- utable to P’s Country X separate unit, is made available to offset income of HPSX. Such income is attributable to P’s interest in HPSX, which is a separate unit. Such in- come also is income of FSZ, a foreign cor- poration that is an owner of an interest in HPSX, which is not a separate unit. However, pursuant to § 1.1503(d)–3(c)(4), there is no for- eign use of the year 1 dual consolidated loss in year 2. This is the case because P’s inter- est in HPSX as of the end of year 1 has not been reduced by more than a de minimis amount, and the portion of the $80x dual con- solidated loss was made available for a for- eign use in year 2 solely as a result of FSZ’s ownership in HPSX and the allocation or carry forward of the dual consolidated loss as a result of such ownership.