Interest Allocation: A Regime Desperately in Need of Sound Policy

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

Accepted Paper Series