TAX 9869 Lecture Notes - Lecture 53: Interest Expense, Gross Income, Foreign Tax Credit

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11 Aug 2020
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Gilti = net cfc tested income [(10% x qbai) net interest expense] Net cfc tested income = cfc tested income cfc tested loss (10% * qbai= qualified business asset investment- interest income over interest expense) Net interest expense = interest income over interest expense. Meals & entertainment interest expense limitation- changed 163j- only able to deduct certain amt of interest exp- 30% (raised w/cares act) Since some limitation formulas, take them and interest expense into account when computing interest income/loss, may not be able to deduct all of it, under us tax principles. Take assets, 10% of qbai, the tax basis of depreciable, tangible assets 10% of that= net deemed intangible return- net interest expense. Have to be given to you on exam to figure out gilti. As a note, when doing dep expense for cfc can"t use accel depreciation type calculations use ads sl dep.

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