Commercial expediency in group funding supports interest deduction and limits corporate guarantee fee attribution.

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....Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.....