Page 637 - Large Business IRS Training Guides

Specified Interest Expense Example 1

US1

100%
60%

CFC1 CFC2

Interest 100x

rata share of

US1’s pro …includes interest
tested income* from… expense (income)
of…

CFC1 100x

CFC2 (60x)

US1 has specified
interest expense of 40x.

*Assume both CFC1 and CFC2 have tested income (not

tested loss). 53