Worldwide Apportionment of Interest Revisited

This article discusses the legislative and other developments on the worldwide interest apportionment approach for computing foreign-source income. It includes a summary of the principal pieces of relevant legislation on the subject, a comparison of their provisions, and describes a few of the legal and other issues raised by the most recent legislation. The article concludes by stating that it is time to correct the problems associated with the current water's edge system of interest apportionment and giving taxpayers the option of using a worldwide interest apportionment approach for computing foreign-source income accomplishes this objective.