Extract to table

and the remaining built-in gain attributable to the other 18 portfolio companies — carries over to the Master Fund and must be respected in the allocation of tax items

IRC § 367(a)(1) provides, in relevant part: "If, in connection with any exchange described in section 332, 351, 354, 356, or 361, a United States person transfers property to a foreign corporation, such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a corporation

" IRC § 367(b) provides, in relevant part: "In the case of any exchange described in section 332, 351, 354, 355, 356, or 361 in connection with which there is no transfer of property described in subsection (a), a foreign corporation shall be considered to be a corporation except to the extent provided in regulations