Stewardship Costs Shouldn’t Be Deemed ‘Allocable,’ Group Says

The Treasury Department shouldn’t deem stewardship expenses to be “directly allocable” to a certain kind of foreign-earned income, a business group said.

In addition, sales, general, and administrative expenses and certain kinds of losses shouldn’t be considered directly allocable to net CFC tested income either, the Working Group for Competitive International Taxation said in a Dec. 10 comment letter released by Treasury on Tuesday. The working group represents 18 US companies including American Express Co., Citigroup Inc., and Microsoft Corp.

Stewardship expenses are costs incurred to oversee an investment. Excluding those expenses from NCTI would allow companies to take more ...