Every indexed document

then the first factor in the definition equals 1

General Explanations of the Administration's Fiscal Year 2010 Revenue

such as the foreign exchange rules under Section 987 in the case of certain

” which are uniquely defined for purposes of the DCL rules.

absent an election to be treated as a corporation).

2004-2 CB 119 (holding that where a domestic corporation and its wholly

the proposal would not take effect until 2011. 85 Given the Obama Administration's

triggering of dual-consolidated losses). Except in cases of U.S. tax avoidance

a foreign eligible entity with a single owner that is organized or created in a

the DRE is treated as a separate entity and its income

and that NOL might also be used for foreign tax purposes against

use of the DCL could occur in both the U.S. and the

a hybrid entity that is a DRE for U.S. tax

is to prevent a single net operating loss (NOL) generated by a DRE from being

as applied to a domestic corporation that owns a

generally treat a DRE as a separate entity. 73 An example of a DRE to

and the consolidated return regulations that

for purposes of the regulations under Section 881

any transaction entered into by a DRE will be taken into account for

the IRS issued proposed regulations under Section 881. 69 Under Prop. Reg.