Tina Smith: “I ask for additional clarification regarding the conferees' intent with respect to the rule in section 422 of the…”

“I ask for additional clarification regarding the conferees' intent with respect to the rule in section 422 of the American Jobs Creation Act of 2004 that disallows deductions for expenses "properly allocated and apportioned to the deductible portion." I would ask for clarification of the type of expenses that may be "properly allocated and apportioned." Would it be reasonable to say that properly allocable and apportioned expenses would not include general and administrative costs not directly related to generating the income being repatriated and such indirect expenses as research and development costs, interest, state and local income taxes, sales and marketing costs, depreciation, and amortization.”