IRS releases interest expense allocation and apportionment regulations

January 2012

Overview

The IRS today issued temporary and proposed regulations on interest expense allocation and apportionment by corporations owning a 10% or greater interest in a partnership, as well as interest expense allocation and apportionment using the fair market value method. These regulations also update the interest allocation regulations to conform to the statutory changes made by the Education Jobs and Medicaid Assistance Act affecting the affiliation of certain foreign corporations for purposes of Section 864(e).

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