remittance
(xii) Remittance. The term remittance means a transfer of property (within the meaning of section 317(a)) by a foreign branch that would be treated as a distribution if the foreign branch were treated as a separate corporation. (xiii) Tentative disregarded basis. The term tentative disregarded basis means, in connection with the transfer of property in a transaction that is disregarded for Federal income tax purposes, the basis that property would have if the disregarded payment made in exchange for the transferred property were treated as the cost of such property under section 1012(a). (4) Examples. The following examples illustrate the application of this paragraph (f). (i) Example 1: Determination of foreign branches and foreign branch owner(A) Facts.