The US government last Thursday announced proposals for temporary regulations related to the apportionment of interest concerning the foreign tax credit
In a statement, the Treasury Department and the Internal Revenue Service stated that:
"The temporary and proposed regulations provide an elective alternative approach for measuring assets for purposes of apportioning interest expense between US and foreign sources under the tax book value method of the current regulations."
Assistant Treasury Secretary Greg Jenner added:
"The new election will permit taxpayers to determine the tax book value of foreign and domestic assets under one consistent depreciation regime. This will eliminate distortions that can arise because foreign assets generally are depreciated more slowly than US assets."
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