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sources without the United States for each of the years in
issue as claimed on petitioner's consolidated returns, the
aggregate interest expense to be apportioned to foreign
sources if there is no netting of interest expense and
interest income, and the aggregate amount to be so
apportioned if there is netting of interest expense and
interest income. The last column of the schedule shows the
difference between the amount of interest to be apportioned
to sources without the United States, assuming that there
is no netting, and the amount of interest to be so
apportioned, assuming that there is netting:
Interest expense allocated and apportioned to sources without the United States
Year Per return No netting Netting Difference
1982 $55,704,104 $55,155,126$17,444,643$37,710,483
1983 50,434,920 47,362,922 17,200,130 30,162,792
1984 54,658,298 50,150,909 19,831,268 30,319,641
1986 45,205,129 45,517,890 37,689,610 7,828,280
206,002,451 198,186,84792,165,651 106,021,196
Thus, as shown above, if there is netting, then the
aggregate interest expense to be allocated and apportioned
to sources without the United States in computing the
overall limitation on petitioner's foreign tax credit under
section 904(a) would be substantially less for each of the
4 years in issue than the interest expense to be allocated
and apportioned to sources without the United States if
there is no netting. This difference is $37,710,483,
$30,162,792, $30,319,641, and $7,828,280, for the years in
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