In allocating interest expense between U.S.and foreign sources,a taxpayer must use the tax basis of assets in determining the proper interest apportionment.
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Q3: The transfer of the assets of a
Q4: In all cases,the sourcing of income is
Q4: The IRS can use § 482 reallocations
Q6: Interest paid to an unrelated party by
Q8: All losses are apportioned against U.S.-source income.
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Q10: A Qualified Business Unit of a U.S.corporation
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Q16: Hendricks Corporation, a domestic corporation, owns 40
Q18: A "U.S. shareholder" for purposes of CFC
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