If a taxpayer is permitted to treat nondomestic production gross receipts as DPGR, pursuant to a safe-harbor or de minimis rule provided in Notice 2005-14, deductions related to those gross receipts must be allocated or apportioned
Besides facing a greater state tax burden, more of their liability is apportioned
to foreign source income, due to the presumption above.
taxpayer's interest expense is to be apportioned
Out of the given amount, Rs180bn have been apportioned
to five large banks, Rs69.
They must weigh these activities against the state tax laws in their residence/domicile to minimize effectively the amount of income apportioned
and allocated to states with high marginal tax rates.
Specifically, the proposed regulations reject the notion that all charitable contributions should be ratably apportioned
and set forth special rules for the allocation of charitable contribution deductions solely to U.
Previously, INR Rs 31 billion were being apportioned
by the government on account of grants for Pakistan Railways to meet its losses and Rs 22.
After allocating gross income to the proper baskets, deductions and taxes must be allocated and apportioned
to gross income to arrive at E&P for each FTC basket.
The Department reasoned that, if it sought to more fairly apportion a corporate taxpayer's foreign dividend income, then the resulting income apportioned
to New Mexico would be only that income earned in New Mexico; therefore, the discrimination problem would be cured.