The Coca-Cola Company, and Includible Subsidiaries - Page 7

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          basis of Bowater Inc. v. Commissioner, 101 T.C. 207 (1993), that            
          petitioner may net interest income against interest expense in              
          determining the amount of interest deduction to be allocated and            
          apportioned in computing combined taxable income under section              
          936 and section 1.861-8(e)(2), Income Tax Regs.  See also General           
          Portland Cement Co. v. United States, 628 F.2d 321 (5th Cir.                
          1980).                                                                      
          II. Discussion                                                              
               A.  Section 936 and Section 1.936-6(b)(1) Q&A 1 & 12, Income           
          Tax Regs.                                                                   
               Under the statutory scheme of section 936, a U.S.                      
          corporation, such as CRI, which elects the application of section           
          936 and meets certain requirements with respect to operating in a           
          possession, is entitled to a credit against the U.S. tax on                 
          certain possession-related income.  Section 936 provides the                
          following:                                                                  
                    SEC. 936(a).  Allowance of Credit.--                              
                         (1) In General.-- * * * if a domestic corporation            
                    elects the application of this section * * * there                
                    shall be allowed as a credit against the tax imposed by           
                    this chapter an amount equal to the portion of the tax            
                    which is attributable to the sum of--                             
                              (A) the taxable income, from sources without            
                         the United States, from--                                    
                                   (i) the active conduct of a trade or               
                              business within a possession of the United              
                              States, or                                              
                                   (ii) the sale or exchange of                       
                              substantially all of the assets used by the             





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