Interest Expense Allocation Under Regulations Section 1.882-5
Section references are to the Internal Revenue Code unless otherwise noted.
2011
Table of Contents
- General Instructions
- Specific Instructions
- Lines 1 Through 9: All Foreign Corporations
- Lines 1 Through 5. Step 1: Determination of Total Value of U.S. Assets
- Lines 6 Through 7c. Step 2: Determination of U.S.-Connected Liabilities - Regulations Section 1.882-5(c)
- Lines 8 and 9. Step 3: Interest Expense Allocation (Including U.S.-Booked Liabilities and U.S.-Booked Interest Expense Included in the Determination of Branch Interest)
- Lines 10 Through 15. Step 3: Adjusted U.S.-Booked Liabilities Method
- Lines 16a Through 20. Step 3: Separate Currency Pools Method
- Lines 21 Through 25. Summary – Interest Expense Allocation and Deduction Under Regulations Section 1.882-5
- Lines 1 Through 9: All Foreign Corporations
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