The Internal Revenue Service has issued final regulations to provide guidance on the allocation and apportionment of interest expense by corporations that own a 10 percent or greater interest in a partnership, along with the allocation and apportionment of interest expense using the fair market value method.
The final regulations in TD 9676 also update the interest allocation regulations to conform to changes made by the Education Jobs and Medicaid Assistance Act of 2010, which affect the affiliation of certain foreign corporations.
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