Portland Corporation Is a U

Short Answer

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?