Sunoco, Inc. and Subsidiaries - Page 22




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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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