The Coca-Cola Company, and Includible Subsidiaries - Page 24

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          interpreted as a directive from Congress to apply the section               
          1.861-8, Income Tax Regs., expense allocation and apportionment             
          regime in performing CTI computations.                                      
               The principles under section 1.861-8, Income Tax Regs.,                
          require that all deductions must be allocated to the class or               
          classes of gross income to which they are factually related.                
          Deductions are incurred with respect to activities and properties           
          that generate particular classes of gross income, or which                  
          generate all classes of gross income, and that are definitely               
          related to those classes of gross income.                                   
               These principles, according to respondent, require that                
          deductions be apportioned between gross income derived from the             
          possession product (the statutory grouping) and other gross                 
          income (the residual grouping) using a method that reasonably               
          reflects the factual relationship between the deductions and the            
          income assigned to the grouping.  Respondent contends that                  
          section 936(h)(5)(C)(ii)(II) adopts a method of apportioning                
          expenses to possession product gross income which turns upon                
          factual relationships.  Petitioner's alleged misapplication of              
          the PCR causes gross misapportionments, according to respondent.            
               Petitioner argues that the plain meaning of Q&A-12 is                  
          consistent with the language and purpose of section                         
          936(h)(5)(C)(ii)(II).  Petitioner contends that section                     
          936(h)(5)(C)(ii)(II) provides only general principles for                   
          component products and does not provide specific guidance for               




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