    | ||
|
This article describes how the new Internal Revenue Code Section 864(e), which provides an opportunity for taxpayers to elect to modify their interest expense allocation for foreign tax credit purposes, will impact US multinationals. This article analyzes new Internal Revenue Code Section 864(e), which provides an opportunity for taxpayers to elect to modify their interest expense allocation for foreign tax credit purposes. In the world of international business, corporations that operate in different countries sometimes pursue reorganizations. They may do this to streamline operations to maintain a competitive advantage. They may also do it to change their corporate 'persona' with a new management and operating structure. When a multinational corporation reorganizes, it takes into consideration the tax implications. This article analyzes a U.S. company's inability to utilize the APB 23 exception on a portion of the outside basis of a subsidiary as a result of the provisions of Subpart F of the U.S. Tax Code. 1 | ||
