What Is Allowable Interest Deduction?
26 CFR § 1.861-9T – Allocation and apportionment of interest expense (temporary). § 1.861-9T Allocation and apportionment of interest expense (temporary).
How are deductions for amortization and depreciation apportioned?
See Regulations section 1.611-1 (c) (4). Amortization. The deduction for amortization is apportioned between an estate or trust and its beneficiaries under the same principles used to apportion the deductions for depreciation and depletion.
Is there any guidance on apportionment of tax?
No guidance is found in the legislation, although it does appear to be generally accepted that any apportionment must be “fair and reasonable”. The Commissioner has sought to assist taxpayers by publishing a number of rulings on the question of apportionment. [3]
How are expenses and losses subject to apportionment?
Thus, expenses and losses will be subject to apportionment under the rules of this section to the extent that such expenses or losses were incurred in consideration of the time value of money. (i) Rule.
