affiliated group

(2) Allocation and apportionment of other expenses Expenses other than interest which are not directly allocable or apportioned to any specific income producing activity shall be allocated and apportioned as if all members of the affiliated group were a single corporation. For purposes of the preceding sentence, the term “affiliated group” has the meaning given such term by section 1504 (determined without regard to paragraph (2) of section 1504(b)).


26 USC § 864(f)(2)

Scoping language

For purposes of this subchapter
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