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IRS Chief Counsel Advice Addresses Interest Expense Allocable to Foreign Firm’s U.S. Insurance Business

April 6, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service Office of previous hitChiefnext hit previous hitCounselnext hit, in a previous hitchiefnext hit previous hitcounselnext hit previous hitadvicenext hit memorandum released April 2, said a previous hitforeignnext hit taxpayer conducting a previous hitU.Snext hit. life previous hitinsurancenext hit previous hitbusinessnext hit must use the allocation method set forth in Treasury Regulations Section 1.882-5 to determine previous hitinterestnext hit previous hitexpensenext hit previous hitallocablenext hit to its previous hitU.Snext hit. branch for purposes of computing its previous hitU.Snext hit. income tax liability for 2001 and 2002 tax years.

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