Taxation and State Taxation -- 1998
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Bowater, Inc. v. Commissioner of Internal Revenue
(U.S. Supreme Court)
Taxation of interest income from foreign sources
The NAM supported Bowater's petition for Supreme Court review of a Second Circuit decision involving the allocation of expenses relating to interest income from foreign sources. The case affects multinationals with interest-generating investments abroad. An NAM survey shows that half of those responding consider this an important issue, with half of those claiming that the case will have an impact on an average of more than $17.5 million in tax liability per company. On January 12, 1998, the Supreme Court declined to hear this appeal.
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