Sunoco, Inc. and Subsidiaries - Page 8




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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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