A * sovereign entity cannot deduct an amount if:
(a) the sovereign entity is covered by section 880 - 125; and
(b) the amount is a loss in respect of any of the following kinds of interest that the sovereign entity holds in another entity:
(i) a * membership interest;
(ii) a * debt interest;
(iii) a * non - share equity interest; and
(c) the requirements in paragraphs 880 - 105(1)(c), (d) and (e) would be satisfied, on the assumptions that:
(i) the amount were * ordinary income or * statutory income; and
(ii) the amount became ordinary income or statutory income of the sovereign entity at the time it arose; and
(iii) references in those paragraphs to the test entity were references to the other entity mentioned in paragraph (b) of this section.