The Foreign Tax Credit's Interest Allocation Rules
Description
This report discusses the "worldwide" allocation of interest rule, which was a provision of the American Jobs Creation Act of 2004 (P.L. 108-357; the Jobs Act). The provision relates to the taxation of multi-national corporations and allows more generous rules for multinationals to use in allocating interest expense for purposes of the U.S. foreign tax credit.
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Description
This report discusses the "worldwide" allocation of interest rule, which was a provision of the American Jobs Creation Act of 2004 (P.L. 108-357; the Jobs Act). The provision relates to the taxation of multi-national corporations and allows more generous rules for multinationals to use in allocating interest expense for purposes of the U.S. foreign tax credit.
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Gravelle, Jane G. & Marples, Donald J.The Foreign Tax Credit's Interest Allocation Rules,
report,
January 28, 2009;
Washington D.C..
(https://digital.library.unt.edu/ark:/67531/metadc743603/:
accessed January 13, 2026),
University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu;
crediting UNT Libraries Government Documents Department.