- 26 - APPENDIX SEC. 265(b). Pro rata Allocation of Interest Expense of Financial Institutions to Tax-Exempt Interest.-- (1) In general.--In the case of a financial institution, no deduction shall be allowed for that portion of the taxpayer’s interest expense which is allocable to tax-exempt interest. (2) Allocation.--For purposes of paragraph (1), the portion of the taxpayer’s interest expense which is allocable to tax-exempt interest is an amount which bears the same ratio to such interest expense as-- (A) the taxpayer’s average adjusted bases (within the meaning of section 1016) of tax-exempt obligations acquired after August 7, 1986, bears to (B) such average adjusted bases for all assets of the taxpayer. SEC. 291(e). Definitions.--For purposes of this section-- (1) Financial institution preference item.--The term “financial institution preference item” includes the following: * * * * * * * (B) Interest on debt to carry tax-exempt obligations acquired after December 31, 1982, and before August 8, 1986.-- (i) In general.--In the case of a financial institution which is a bank (as defined in section 585(a)(2)), the amount of interest onPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: March 27, 2008