Interest Allocation: A Regime Desperately in Need of Sound Policy

30 Pages Posted: 29 Aug 2010  

Bret Wells

University of Houston Law Center

Date Written: August 26, 2010

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.

Keywords: Section 861, interest expense apportionment

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: https://ssrn.com/abstract=1666445

Bret Wells (Contact Author)

University of Houston Law Center ( email )

4604 Calhoun Road
Houston, TX 77204-6060
United States

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