Page 653 - Large Business IRS Training Guides

Example 2 cont’d 2

FACTS (Cont’d):

properly allocable
USP
• The deductions

to the gross tested income of
CFC1, CFC2, CFC3 and CFC4 are

and 300x,
200x, 50x, 100x,
CFC1 CFC2 CFC3 CFC4
respectively.

• The tested interest expense of
CFC4 is
CFC1, CFC2, CFC3 and

CFC1 CFC2 CFC3 CFC4 0x, 30x, 10x, and 100x,
respectively.

Gross TI / (TL) 700x 150x 400x 0
• None of the CFCs have tested
Tangible property 100x 600x 0 800x
interest income.

Deductions 200x 50x 100x 300x
properly allocable

Tested interest 0x 30x 10x 100x
expense

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