The U.S. Tax Court issued an opinion on 16 March 2022 concerning the apportionment of interest expense with respect to stock in a controlled foreign corporation (CFC) for purposes of the computation of a foreign tax credit. The case is summarized in the opinion as follows: The Petitioner - "P" (AptarGroup Inc.) owns stock in a CFC that apportioned interest expense under the modified gross income method. P claimed a foreign tax credit under I.R.C. § 904 with respect to tax imposed on its income from the CFC. To determine the amount of the foreign tax credit, P characterized its...