We believe that the diversity and professional training of our members enable us to bring an important, balanced, and practical perspective to the issues raised by the proposed regulations under section 861, relating to the allocation and apportionment of interest expense
The analyst said retailers could realize interest expense
savings in two forms.
Because M's statutory interest expense
is mandated by the State of Texas, it is clearly 'allowable by the laws of the jurisdiction' under Sec.
The treatment of interest expense
and certain balance sheet items are the most significant and accordingly are the focus of this article.
Under those rules, interest expense
incurred by one member of an affiliated group can be allocated to the foreign source income of another member.
The negative free cash flow is primarily driven by increased cash interest expense
and capital expenditures.
In order not to frustrate the decedent's intent, interest expense
had to be allocated against the estate's income, not corpus.
2 percent, we are saving approximately $32 million in interest expense
over the life of these low-interest loans.
parent company may net interest income against its interest expense
in determining the amount of its interest deduction to be allocated and apportioned in computing combined taxable income for domestic international sales corporation (DISC) purposes.
The company expects the call of the senior subordinated notes to close in February and expects to see the favorable impact of lower interest expense
in the second quarter of 2005.
1 (h) to the extent the taxpayer elects to treat the capital gain as ordinary income (since the incremental interest expense
deduction produces only a 28% income tax benefit).
These rating actions also consider The Atlantic's ability to generate future earnings and accumulate capital, while taking into account its historically weak underwriting and operating performance, continued interest expense
associated with funds-held reinsurance and potential for continued adverse prior year loss reserve development.