1. Overview and Introduction to Sourcing Allocation and Apportionment Rules
A 40-page handout
- Benefits of allocating and apportioning expenses
- Statutory calculation require expenses to be allocated and apportioned
Rob Arthur, Parente Randolph
2. Domestic Production Activities Deduction
A 35-page handout
Jim Wittmer, Grant Thornton, Philadelphia, PA
Rich Shevak, Grant Thornton , Washington, DC
3. Identifying and Sourcing Income Streams
A 13-page handout
- Is income subject to withholding
- Also, which foreign country
- Is income subject to U.S. tax
- Is there a foreign tax credit available
- Source of income and deduction since § 904 limitation based on taxable income
Edward Dembitz, The Law Office of Edward Dembitz, Pittsburgh, PA
4. Supportive Expenses Under the New Services Regulations and Stewardship Expenses
A 27-page handout
- Old 1968 service regs
- Goals of temporary regs
- Incorporate §482-1 general rules [-9T(a)]
- Narrowed “shareholder services” definition
- Services cost method
Raymond Wynman, Ernst & Young, Philadelphia, PA
Steven Wrappe, Ernst & Young, Minneapolis, MN
5. Allocation & Apportionment of Expenses of Research and Development Expenses
A 46-page handout
- Allocation & apportionment affects a wide range of international tax computations
- Foreign tax credit (FTC) limitations
- Export Income for IC-DISCs
- Qualified production activity income
- Effectively connected income (ECI)
- Foreign base company income (FBCI) of a CFC
Charles Russo, Parente Randolph, Williamsport, PA
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6. Preparing Forms 1118 and 8903 and other new developments in International Reporting – Improving Efficiency
A 53-page handout accompanied by forms 1118 and 1120 and case information including Hart vs. U.S., Bank of America vs. U.S and Morrison-Knudsen Co., Inc. vs. U.S.
- Forms 1118 and other developments in international reporting
- New in 2007 - categories of income eliminated
- Form 8903 – domestic production activities deduction
- Is there a benefit or not?
Edward Umling, Parente Randolph, Pittsburgh, PA
7. Allocating & Apportioning S, G & A Expenses
A 30-page handout
- Selling, general and administrative (“SGA”)
- Intragroup Services
- 1968 Regulations
- Temporary regulations TD 9278, 8/4/06
- “Low margin” covered services
Richard Sackin, Amper, Politziner & Mattia, P.C., Edison, NJ
8. Allocation and Apportionment of Interest Expense
A 24-page handout
- Historical background
- What is interest?
- Why do we care?
- Who do these rules affect
- What allocation methodologies do we use?
- Inbound vs. outbound
- What does the future hold?
Robert Whitall, Cohen & Company, Cleveland, OH
9. Interaction of DPAD and FTC
A 16-page handout
- The equations
- Consistency rule
- Interest apportionment
- Stewardship
- R & D
Steve Fox, U.S. Tax Advantage, New York, NY
10. Allocation and Apportionment of Legal, Charitable and other Expenses; Allocation and Apportionment of State Taxes
A 37-page handout
- Legal and accounting fees
- Charitable contributions
- State income taxes
- State taxes
Robert Verzi, Habif, Arogeti & Wynne, LLP |
