2008-12 is whether a noncorporate limited partner's distributive share of interest expense
incurred in the trade or business of trading securities by the partnership is subject to the Sec.
Allocating a domestic parent's interest expense
Our analysis shows that Target could realize the largest savings in its annual interest expense
if it refinanced its debt under our assumptions," Exstein explained, adding that the retailer could see savings of $17.
incurred in connection with a passive activity is classified as passive interest expense
Investment expense, such as brokerage management fees, is subject to 2% of the adjusted gross income (AGI) floor and is reported on the "other expenses" line (in the "Job Expenses and Certain Miscellaneous Deductions" section) of Form 1040, Schedule A, Itemized Deductions, while investment interest expense
is not subject to the 2%-of-AGI floor and is reported on the "investment interest" line (in the "Interest You Paid" section) of Schedule A.
Section 864(e) of the Code provides the allocation and apportionment of interest expense
to be made on the basis of assets rather than gross income.
172(b)(1)(E) applies is less than the average yearly interest expense
deduction for the three tax years prior to the CERT, there is no CERT limit on the NOLs.
Despite the adoption of the concept of fungibility, the affiliated group concept that underlies the current interest expense
allocation regime is based on an affiliated U.
But if the $50,000 is invested in growth stocks that pay only $500 in dividends, current deductions are limited to the net investment income of $500; the remaining interest expense
of $4,500 must be carried forward indefinitely.
Under present accounting, the entire proceeds of issuance would be recognized as a liability, and interest expense
of $1,950,000 ($50,000,000 x 7.