Sunoco, Inc. and Subsidiaries - Page 47




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             taxpayer's "entire taxable income for the same taxable                   
             year".  Sec. 904(a).  This raises a question about where in              
             the regulations is there authority to reduce "gross income"              
             by the amount of netted interest.                                        
                  Second, an equally important consequence of netting is              
             the fact that it increases the ratio under section 904(a),               
             and thus increases the amount of foreign tax credit, only                
             to the extent that the interest income that is absorbed by               
             interest expense in the netting process is from U.S.                     
             sources.  To the extent that a relatively greater amount of              
             the interest income absorbed in the netting process is from              
             foreign sources, then netting produces a lower ratio under               
             section 904(a) than not netting.                                         
                  In the above example, we assumed that all of the                    
             interest income, $200,000, was from U.S. sources.  In that               
             case, the section 904(a) ratio computed without netting was              
             28 percent but was increased to 37.23 percent by netting.                
             On the other hand, if we assume that the interest income is              
             entirely from foreign sources, then the section 904(a)                   
             ratio, without netting, is 52 percent, computed as follows:              













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