Common use of Result Clause in Contracts

Result. As a result of the transfer of as- sets from P to FSX, a portion of the year 1 dual consolidated loss is available for a for- eign use. This is the case because a portion of the basis in FBX’s assets, which gave rise to depreciation deductions that were taken into account in computing the year 1 dual consolidated loss, will give rise to a depre- ciation deduction under Country X laws that will be available, under U.S. tax principles, to offset the income of FSX, a foreign cor- poration, in year 2. However, the aggregate adjusted basis of all the assets transferred by P to FSX, within the 12-month period ending at the end of year 2, is less than 10 percent of the aggregate adjusted basis of all of FBX’s assets at the beginning of such 12- month period. Moreover, the aggregate ad- justed basis of the assets transferred by P to FSX at any time during the certification pe- riod is less than 30 percent of the aggregate adjusted basis of FBX’s assets held at the end of year 1. In addition, the item of deduction giving rise to the foreign use is being made available solely as a result of the adjusted basis of the transferred assets being deter- mined in whole, or in part, by reference to the adjusted basis of such transferred assets in the hands of FBX. As a result, this transfer will not result in a foreign use pursuant to § 1.1503(d)–3(c)(6).