General Dynamics Corporation and Subsidiaries - Page 25

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               Rather than creating a new method of cost allocation within            
          the DISC provisions, Congress intended that taxpayers use the               
          method for allocating costs under section 1.861-8, Income Tax               
          Regs.  The intended method for allocating expenses in the CTI               
          computations appears consistent throughout the legislative                  
          history of the DISC provisions, which states:                               
               the combined taxable income from the sale of the export                
               property is to be determined generally in accordance                   
               with the principles applicable under section 861 for                   
               determining the source (within or without the United                   
               States) of the income of a single entity with                          
               operations in more than one country.  These rules                      
               generally allocate to each item of gross income all                    
               expenses directly related thereto, and then apportion                  
               other expenses among all items of gross income on a                    
               ratable basis.  * * *  [Emphasis added.]                               
                                                                                     
          H. Rept. 92-533, supra at 74, 1972-1 C.B. at 538; accord S. Rept.           
          92-437, supra at 107, 1972-1 C.B. at 619.  Consistent with                  
          legislative history, the regulations provide that taxpayers must            
          allocate and apportion their costs (other than costs of goods               
          sold) "in a manner consistent with the rules set forth in �                 
          1.861-8."  Sec. 1.994-1(c)(6)(iii), Income Tax Regs.; see sec.              
          1.925(a)-1T(c)(6)(iii)(D), Temporary Income Tax Regs., supra.               
               In general, section 1.861-8, Income Tax Regs., provides                
          geographic sourcing rules to allocate and apportion expenses                
          between the United States and foreign countries.  It also                   
          provides rules for determining taxable income from specific                 
          activities and for allocating income and deductions to those                
          activities under other sections of the Code referred to as                  





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