Abstract

http://ssrn.com/abstract=1666445
 


 



Interest Allocation: A Regime Desperately in Need of Sound Policy


Bret Wells


University of Houston Law Center

August 26, 2010

Tax Lawyer , Vol. 53, p. 859, 2000
U of Houston Law Center No. 2010-A-27

Abstract:     
This article examines the various tax policy approaches that are available for allocating and apportioning US interest expense. After considering the underlying tax policy issues at stake, the author seeks to demonstrate what is wrong with the approach set forth under current law and proposes an alternative allocation regime that is consistent with sound international tax principles.

Number of Pages in PDF File: 30

Keywords: Section 861, interest expense apportionment


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Date posted: August 29, 2010  

Suggested Citation

Wells, Bret, Interest Allocation: A Regime Desperately in Need of Sound Policy (August 26, 2010). Tax Lawyer , Vol. 53, p. 859, 2000; U of Houston Law Center No. 2010-A-27. Available at SSRN: http://ssrn.com/abstract=1666445

Contact Information

Bret Wells (Contact Author)
University of Houston Law Center ( email )
4604 Calhoun Road
Houston, TX 77204-6060
United States

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