International Tax

The Allocation and Apportionment of Deductions (Portfolio 6640)

  • This Portfolio sets forth and analyzes the rules for allocating and apportioning deductions in various contexts.

Description

Bloomberg Tax Portfolio, The Allocation and Apportionment of Deductions anallyzes the rules for allocating and apportioning deductions. 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.

Because of the complexity of the rules, a substantial part of the Portfolio focuses on the rules for allocating and apportioning interest deductions and research and experimental deductions. The Portfolio also discusses the rules for allocating and apportioning other deductions, including those for state and local taxes, stewardship and supportive expenses, charitable contributions, losses from the disposition of capital assets, and net operating losses.

Table of Contents

I. Introduction
II. General Principles
III. Allocation and Apportionment of Interest Expense
IV. Allocation and Apportionment of R& E Expense
V. Allocation and Apportionment of Other Deductions
VI. Allocation of Expenses at the Controlled Foreign Corporation Level

Diane L. Renfroe
Diane L. Renfroe
gannon-james-2015
James Gannon
Partner
Deloitte Tax LLP
Daniel-Lange
Daniel Lange
Deloitte Global Leader, Tax & Legal
Deloitte Tax LLP
Richard A. Gordon
Richard A. Gordon
Merrill Lynch & Co.
Andrew C. Newman
Andrew C. Newman
Deloitte Tax LLP
Howard_S._Engle_BTAX_052019
Howard S. Engle
Partner (Retired)
Deloitte Tax LLP
Cederoth_Karen_BTAX_052019
Karen E. Cederoth
Tax Partner
Deloitte Tax LLP
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