# Prop. Treas. Reg. § 1.861-11: 

Proposed regulation, not in force. REG-105847-05, 70 FR 67220, published 2005-11-04 <https://www.federalregister.gov/documents/2005/11/04/05-21484/income-attributable-to-domestic-production-activities>. Interprets 26 U.S.C. § 861.

3. The IRS and Treasury Department note that there are special rules regarding the application of the section 861 method in the case of affiliated groups. See section 864(e)(5) and (6); see also §§ 1.861-11(d)(7), 1.861-11T(d)(6), 1.861-14(d) and 1.861-14T. Comments are requested regarding whether additional guidance is needed to clarify how the rules under §§ 1.861-11T(c) and (g) and 1.861-14T(c) apply under the section 861 method to allocate and apportion interest and other expenses such as research and experimentation expenses in computing QPAI of the members of such affiliated groups in which otherwise includible corporations are owned indirectly through foreign corporations and partnerships.