The allocation and apportionment of deductions /

The allocation and apportionment of deductions /

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Bibliographic Details
Author / Creator:	Goldstein, Seth, author.
Imprint:	Arlington, VA : Tax Management, [2006]-
Description:	1 online resource
Language:	English
Series:	U.S. international portfolios ; 6640 Tax management portfolios ; 6640.
Subject:	Income tax deductions -- United States.
Format:	E-Resource Journal
URL for this record:	http://pi.lib.uchicago.edu/1001/cat/bib/5669686

Hidden Bibliographic Details
Title varies:	Allocation and apportionment of expenses--Regs. [section] 1.861-8
Other authors / contributors:	Gannon, James, author. Halpern, Irwin, author. Elsbernd, Janet, author. Renfroe, Diane L., author. Gordon, Richard A., author. Tax Management Inc., issuing body.
Frequency:	Updated irregularly
Notes:	Authors: Diane L. Renfroe ... [et al.], . Formerly published in Washington, D.C., 2006-2007. Rev. ed. of: Allocation and apportionment of expenses--Regs. [section] 1.861-8 / by Richard A. Gordon ... [et al.]. Published as Tax Management portfolio 906-2nd, . Includes bibliographical references. Description based on contents viewed on January 14, 2016; title from description page.
Summary:	"... describes and analyzes the rules for allocating and apportioning deductions in various contexts, including in determining a U.S. person's foreign-source taxable income for purposes of the foreign tax credit limitation, a controlled foreign corporation's subpart F income, and the character of payments made to related parties under the foreign tax credit rules. In general, deductions must be allocated to the gross income to which they relate (defined as narrowly as possible) and then apportioned among the relevant "statutory" and "residual" groupings of income (e.g., foreign-source income within a particular foreign tax credit "basket" and all other income) within that set of gross income."
Other form:	Print version: Goldstein, Seth. Allocation and apportionment of deductions. Arlington, VA : Tax Management Inc., [2015]- 9781633590915

Table of Contents:

Detailed analysis. Introduction
General principles
Allocation and apportionment of interest expense
Allocation and apportionment of R&E expenses
Allocation and apportionment of other deductions
Allocation and apportionment of expenses at the controlled foreign corporation level
Working papers.