The Coca-Cola Company, and Includible Subsidiaries - Page 17

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          product, i.e., syrup and soft drink, are determined under section           
          1.861-8, Income Tax Regs., as described in section 1.936-6(b)(1),           
          Q&A-1, Income Tax Regs.  These expenses include, inter alia,                
          research and development, experimental, interest, marketing,                
          distribution, and advertising expenses.  Sec. 1.936-6(b)(1),                
          Income Tax Regs.                                                            
               We provide the following examples for illustration:                    
                                      Example 1                                       
               When petitioner sells concentrate as concentrate, i.e., in             
          unchanged form, to unrelated third parties, CTI is determined as            
          follows:                                                                    
                    Item                                  Amount                      
               Gross income from the sale                                             
          of concentrate per unit1                  $2.24                             
          Total USA expenses                          (1.48)                          
               Combined taxable income                       .76                      
               1Concentrate is sold in units; syrup and soft drinks are               
          sold in equivalent gallons.                                                 
               In this example, the PCR is not applicable because the                 
          concentrate is being sold in unchanged form and not as a                    
          component of something larger.  Here, Q&A-1 determines the                  
          computation of CTI, requiring that all expenses factually related           
          to the concentrate be allocated and apportioned in full to the              
          income derived from the sale of the concentrate as concentrate.             
          Thus, 50 percent of the CTI is 38 cents per unit, resulting in a            






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