73 See Reg. 1.1503(d). ——————————— Reg. 1.1503(d)-1(b)(3). 3 TD 9315, 3/16/07. a Reg. 1.1503(d)-1(b)(2). ——— TD 9315, 3/16/07. = Id.; Section 1503(d)(1). The DCL rules also specifically speak about situations involving “transparent entities,” which are uniquely defined for purposes of the DCL rules. —_—_—_ See generally Reg. 1.1503(d)-5. ns There are also other narrow areas where the IRS has indicated it will treat a DRE as separate from its sole owner, such as the foreign exchange rules under Section 987 in the case of certain DREs that are qualified business units and have a different functional currency than their U.S. parent. ——$< ns See Dept. of Treasury, General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (May 2009). ——$<$< << President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens. —————_——___ See supra footnote 77. ————$— Id. — Id. © 2009 Thomson Reuters/RIA. All rights reserved. HOUSE_OVERSIGHT_026597