Tax Type
Corporation Income Tax
Description
Foreign source income; Interest income
Topic
Computation of Income
Date Issued
06-28-1991
June 28, 1991
Re: §58.1-1821 Application; Corporation Income Tax
Dear************************
This is in response to your letter of April 19, 1991, in which you applied for correction of an assessment of corporation income tax. You object to the auditor's treatment of certain interest income that you claim qualifies for Virginia's foreign source income subtraction, net of related expenses that are also sourced without the United States pursuant to I.R.C. §861 et seq.
It appears that there are no policy issues in dispute at this time. The auditor disallowed a subtraction because you failed to supply sufficient information at the time of the audit, although requested. You have supplied additional information with your letter.
Accordingly, I am referring your additional information to the auditor for review. If she is satisfied that the information you have supplied adequately details the nature of the income and expenses in question, and reconciles it to the information actually reported in your federal consolidated return, she will make the appropriate adjustments to the audit report and assessment. If, after the auditor has completed her review, you believe the assessment is still erroneous, you may reapply for correction under Va. Code §58.1-1821.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner