Sunoco, Inc. and Subsidiaries - Page 46




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             Thus, taxpayer's taxable income, i.e., the difference                    
             between the gross income in both groupings and the                       
             aggregate expenses allocated and apportioned thereto, will               
             be overstated, unless the taxpayer's total gross income is               
             reduced by the amount of interest income that was offset.                
                  Continuing the above example, if interest expense and               
             interest income are netted for purposes of allocating                    
             interest expenses but the amount of interest income offset               
             by netting is not removed from the taxpayer's gross income,              
             then the computation contemplated by section 904(a) would                
             be as follows:                                                           

             With netting            Total     U.S. source  Foreign source            
             Gross income                                                             
             Operating income     $1,300,000   $800,000     $500,000                  
             Interest income      200,000       200,000        -0-                    
             Total                1,500,000    1,000,000    500,000                   
             Gross income ratio   100%         66.67%       33.33%                    
             Expenses                                                                 
             Operating expenses   500,000      300,000      200,000                   
             Interest expense        175,000     116,667       58,333                 
             Total                675,000      416,667      258,333                   
             Taxable income       825,000      583,333      241,667                   
             Sec. 904(a) ratio         1132%    193.3333%    138.6667%                

             1 Based upon taxable income of $625,000.                                 

             Thus, as illustrated above, if the taxpayer's gross income               
             is not reduced, then the taxpayer's taxable income,                      
             $625,000, would be overstated by the amount of the interest              
             income that is offset by interest expense, $200,000, and                 
             the section 904(a) ratio would not be based upon the                     





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