Cheyenne Corporation Is a U

Short Answer

Cheyenne Corporation is a U.S.corporation engaged in the manufacture and sale of mining equipment.The company handles its export sales through sales branches in Canada and Mexico.The average tax book value of Cheyenne's assets for the year was $200 million,of which $100 million generated U.S.source income and $100 million generated foreign source income.The average fair market value of Cheyenne's assets was $600 million,of which $400 million generated U.S.source income and $200 million generated foreign source income.Cheyenne's total interest expense for the year was $30 million.What is the minimum amount of interest expense that Cheyenne can apportion against its foreign source gross income for foreign tax credit purposes,assuming the company can elect either apportionment method?