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BNA Portfolio Provides Update on Allocation and Apportionment of Deductions

NEWS RELEASE

Contacts:
Mark Carrington
(202) 530-1728

Washington, DC (April 10, 2007) – BNA®, publisher of the authoritative and universally recognized Tax Management Portfolio series, has released the latest addition to its Foreign Income library. Portfolio 906-2nd, The Allocation and Apportionment of Deductions, provides up-to-date information on the rules and regulations governing allocation and apportionment of deductions in various business situations.

The rules for allocation and apportionment can be complicated—in general, deductions must be allocated to gross income, then apportioned within "statutory" and "residual" income groupings.  This fully revised and updated Portfolio analyzes the current rules for allocation and apportionment in various contexts, including determining a U.S. individual's foreign-source taxable income for purposes of foreign tax credit limitations, a controlled foreign corporation's Subpart F income, and payments made to related parties under foreign tax credit rules.

A major focus of discussion is the particularly complex rules regarding allocation and apportionment of interest deductions and research and experimental deductions.  Other topics include deductions for state and local taxes, stewardship and supportive expenses, charitable contributions, losses from disposition of capital assets, and net operating losses. 

This Portfolio may be cited as Renfroe, Gannon, Lange, Gordon, et al., 906-2nd T.M., The Allocation and Apportionment of Deductions.

Diane L. Renfroe, Tax Principal, Washington International Tax Group, Deloitte Tax LLP; Adjunct Professor, LLM International Tax Program, Georgetown University Law Center.  Author of numerous articles on international tax issues and developments and frequent speaker at seminars on international tax issues.                 

James Gannon, Tax Partner, Washington International Tax Group, Deloitte Tax LLP.  Member of AICPA and Illinois Society of CPAs.

Daniel S. Lange, Managing Partner, U.S. International Tax practice, Deloitte Tax LLP.  Member of AICPA and WICPA; speaker and author on international tax issues.                  

Richard A. Gordon, Tax Principal, Washington International Tax Group, Deloitte Tax LLP, 2002-2005 (retired).  Member of ABA; author and speaker on international tax issues.                     

Andrew C. Newman, Tax Partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois.  Member of AICPA, Illinois CPA Society, International Fiscal Association, and Chicago Counsel on Foreign Relations; author and speaker on international tax issues.

Howard S. Engle, Partner, Deloitte Tax LLP, Chicago, Illinois; Adjunct Faculty and Chair, Graduate Tax Program.  Speaker and author on international tax issues; editor of the International Tax Developments column in Journal of Corporate Taxation.           

Karen E. Cederoth, Tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois; Instructor, DePaul University, Masters in Tax Program.        

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About BNA®
BNA is the foremost publisher of print and electronic news, analysis, and reference products, including the recently launched Accounting Policy & Practice Series.  It provides intensive coverage of legal and regulatory developments for professionals in business and government. BNA is the oldest wholly employee-owned company in the United States, and produces more than 200 news and information services — including Daily Labor Report and Daily Tax Report — widely respected for comprehensive and objective reporting and analysis.

For more information about the BNA Tax Management Portfolios, call (800) 372.1033.