Sunoco, Inc. and Subsidiaries - Page 43




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             in section 1.861-8(e)(2)(i), Income Tax Regs., simply to                 
             explain why the rules specifically dealing with interest                 
             expenses allocate interest expenses to all of the                        
             taxpayer's gross income, whereas the rules of general                    
             applicability treat other deductions as related to one                   
             or more classes of income.                                               
                  In order to facilitate our discussion of the                        
             positions of the parties, it is helpful to review the                    
             following example.  Assume that during the year a taxpayer,              
             a domestic corporation, had gross operating income from                  
             domestic sales of $800,000, gross operating income from                  
             foreign sales of $500,000, operating expenses of $300,000                
             attributable to domestic sales, and operating expenses of                
             $200,000 attributable to foreign sales.  Assume further                  
             that, during the same year, the taxpayer realized interest               
             income from U.S. sources of $200,000 and interest expense                
             of $375,000.  Finally, assume that the ratio of the value                
             of the assets which relate to activities and properties                  
             that generate foreign source income to the value of all                  
             of the taxpayer's assets is the same as the ratio of the                 
             taxpayer's gross income from foreign sources to total gross              
             income.  Based upon these facts, the computation of the                  
             taxpayer's taxable income from U.S. and foreign sources,                 
             assuming that netting is not permitted, and the proportion               






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