Worldwide Interest Apportionment Has Arrived: What Do We Do Now?

Tax Notes Federal

Christopher P. Bowers Paul W. Oosterhuis Joshua G. Rabon

Partner Christopher Bowers, of counsel Paul Oosterhuis and associate Joshua Rabon explore the technical and policy questions that taxpayers must consider in evaluating a worldwide apportionment election under Internal Revenue Code Section 864(f) in the absence of statutory updates or administrative guidance on implementation of the 16-year-old provision.