Qwan, a U.S. corporation, reports $250,000 interest expense for the tax year. None of the interest relates to nonrecourse debt or loans from affiliated corporations. Qwan’s U.S. and foreign assets are reported as follows. Fair market value: U.S. assets $ 5,000,000 Foreign assets $10,000,000 Tax book value: U.S. assets $ 2,000,000 Foreign assets $ 6,000,000 How should Qwan assign its interest expense between U.S. and foreign sources to maximize its FTC for the current year?
