Full text
begins on or after the first day of the particular taxpayer’s first functional currency year;
begins on or after the first day of the particular taxpayer’s first functional currency year;
begins on or after the first day of the particular taxpayer’s first functional currency year;
ends at least six months after the day that is six months before the end of the particular taxpayer’s first functional currency year;
where a debt obligation is denominated in a currency other than the taxpayer’s functional currency for the particular functional currency year, any amount determined under element B in the formula in subparagraph (i) or element G in the formula in subparagraph (ii) is to be determined with reference to the relative value of that currency and the taxpayer’s functional currency for the particular functional currency year at the beginning of the initial functional currency year of the taxpayer, and