The allocation and apportionment of deductions / Seth Goldstein, Esq. (Deloitte Tax LLP, Washington, D.C.), James Gannon (Deloitte Tax LLP, Washington, D.C.), Irwin Halpern, Esq. (Deloitte Tax LLP, Washington, D.C.), Janet Elsbernd (Deloitte Tax LLP, Milwaukee, WI).

Allocation and apportionment of expenses--Regs. [section] 1.861-8.

Arlington, VA : Tax Management, [2006]-

1 online resource.

Updated irregularly.

Tax management portfolios ; 6640.

"... 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.], <oct. 4, 2007>.
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, <oct. 4, 2007>.

Includes bibliographical references.

Mode of access: World Wide Web.

Description based on contents viewed on January 14, 2016; title from description page.

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Print version: Goldstein, Seth. Allocation and apportionment of deductions. Arlington, VA : Tax Management Inc., [2015]-

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