"... describes and analyzes the rules for allocating and apportioning deductions in various contexts, including in determining a U.S. person's foreign-source taxable income for purposes of the foreign tax credit limitation, a controlled foreign corporation's subpart F income, and the character of payments made to related parties under the foreign tax credit rules. In general, deductions must be allocated to the gross income to which they relate (defined as narrowly as possible) and then apportioned among the relevant "statutory" and "residual" groupings of income (e.g., foreign-source income within a particular foreign tax credit "basket" and all other income) within that set of gross income."
Authors: Diane L. Renfroe ... [et al.], . Formerly published in Washington, D.C., 2006-2007. Rev. ed. of: Allocation and apportionment of expenses--Regs. [section] 1.861-8 / by Richard A. Gordon ... [et al.]. Published as Tax Management portfolio 906-2nd, .
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction General principles Allocation and apportionment of interest expense Allocation and apportionment of R&E expenses Allocation and apportionment of other deductions Allocation and apportionment of expenses at the controlled foreign corporation level Working papers.
Digital File Characteristics
System Details Note
Mode of access: World Wide Web.
Source of Description
Description based on contents viewed on January 14, 2016; title from description page.
Available in Other Form
Print version: Goldstein, Seth. Allocation and apportionment of deductions. Arlington, VA : Tax Management Inc., -