- 46 - 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 thePage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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