30 Pages Posted: 29 Aug 2010
Date Written: August 26, 2010
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: 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