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Portland Corporation Is a U

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Portland Corporation is a U.S.corporation engaged in the manufacture and sale of fishing equipment.The company handles its export sales through sales branches in Canada and Norway.The average tax book value of Portland's assets for the year was $300 million,of which $250 million generated U.S.source income and $50 million generated foreign source income.The average fair market value of Portland's assets was $500 million,of which $400 million generated U.S.source income and $100 million generated foreign source income.Portland's total interest expense for the year was $24 million.What is the minimum amount of interest expense that Portland can apportion against its foreign source gross income for foreign tax credit purposes,assuming the company can elect either apportionment method?


Definitions:

Employee Salaries

The total amount paid to employees for their services over a specific period.

Wages

Payments made to employees as compensation for their labor, calculated on an hourly, daily, or piecework basis.

Net Operating Income

Income from a company's everyday business operations, excluding taxes and interest expenses; a key indicator of a company’s financial performance.

Planning Budget

A budget designed at the beginning of a budgeting period that is based on projected values and assumptions for that period.

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