- 22 - 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 inPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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