Non-branch property.

(B) Non-branch property. The portion of the amount previously recognized under section 904(3) upon a transfer of non-branch property that was attributable to the losses of the foreign branch shall be the sum, over the taxable years in which the transferor sustained an overall foreign loss some portion of which was recaptured on the disposition, of the recaptured portions of those overall foreign losses after multiplication by the following fraction:
(6) Amounts previously recognized under the rules of this section. The previously deducted losses shall be reduced by the amounts previously recognized under the rules of this section upon a previous transfer of assets of the foreign branch.
(f) Example. The rules of paragraphs (b) through (e) of this section are illustrated by the following example.


26 CFR § 1.367(a)-6T

Scoping language

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