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Petitioner chose to use the foreign tax credit under
section 901(a) in computing the tax liability of its
affiliated group of corporations for consolidated return
years 1982, 1983, 1984, and 1986. In computing the overall
limitation on the credit under section 904(a), petitioner
allocated and apportioned a portion of the interest expense
of each member of the affiliated group to sources without
the United States for purposes of computing the numerator
of the limiting fraction under section 904(a); i.e.,
taxable income from sources without the United States.
The following schedule sets forth the deduction for
interest claimed by each member of petitioner's affiliated
group for each of the years in issue, the portion of such
amount that was allocated and apportioned to sources
without the United States for each year, and the ratio of
the latter to the former:
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