- 68 - appropriate allocation of expenses and interest under the passive loss rule. The conferees anticipate that regulations providing guidance to taxpayers with respect to interest allocation will be issued by December 31, 1986. These regulations should be consistent with the purpose of the passive loss rules to prevent sheltering of income from personal services and portfolio income with passive losses. Moreover, the regulations should attempt to avoid inconsistent allocation of interest deductions under different Code provisions.4 In the case of entities, a proper method of allocation may include, for example, allocation of interest to portfolio income on the basis of assets, although there may be situations in which tracing is appropriate because of the integrated nature of the transactions involved. Because of the difficulty of recordkeeping that would be required were interest expense of individuals allocated rather than traced, it is anticipated that, in the case of individuals, interest expense generally will be traced to the asset or activity which is purchased or carried by incurring or continuing the underlying indebtedness. _____________________ 4 For example, an interest deduction that is disallowed under section 265 [relating to expenses and interest relating to tax-exempt income] or 291 [relating to special rules relating to corporate preference items] should not be allowed, capitalized, or suspended under another provision. [H. Conf. Rept. 99-841, at II-146, supra, 1986-3 C.B. (Vol. 4), at 146.] (6) 1986 Blue Book On May 4, 1987, the staff of the Joint Committee on Taxation published its General Explanation of the Tax Reform Act of 1986 (1986 Blue Book), which states in pertinent part as follows (pp. 262-264, 266): C. Interest Deduction Limitations (Sec. 511 of the Act and secs. 163(d) and (h) of the Code)55Page: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
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