Foreign Tax Credits for U.S. Taxpayers: Dealing With New Restrictions

Description

The Education Jobs and Medicaid Assistance Act of 2010, signed into law on Aug. 10, imposes significant new restrictions on U.S.-based multi-nationals and companies with business dealings with foreign entities. Some provisions took effect immediately, while others are effective Jan. 1, 2011.

Taxpayers used to claiming foreign tax credits must brace for an end to credit-splitting, credit denials for a portion of foreign tax paid on a covered asset acquisition, and separate credit limits on tax treaty items, among other changes. Plus, the 80/20 test for withholding ends on Jan. 1, 2011.

The government aims to raise $10 billion in extra taxes over ten years through this new law. Accounting advisors and their clients must prepare immediately to navigate the complex technical terms of the bill. Given the immediate effective dates, waiting for administrative regs is not prudent.

Listen as our panel of experienced tax advisors analyzes the international tax implications of the new federal law, helping you quickly get to work on compliance adjustments and alter your company's tax planning.

Outline

1. International tax increases included in Education Jobs and Medicaid Assistance Act of 2010
   1. International tax extenders shifted from separate tax extender bill onto this legislation
   2. Prohibition against foreign tax credit-splitting
   3. Denial of foreign tax credits for disqualified portion of foreign tax paid on covered asset acquisition
   4. Separate foreign tax credit limitation on tax treaty items
   5. Limit on foreign taxes a U.S. shareholder is deemed to pay under Sect. 956 inclusions
   6. Prevention of reduction of foreign subsidiary’s earnings and profits in some Sect. 304 redemptions
   7. Tightening of affiliation rules for interest expense
   8. Repeal of 80/20 rules for interest paid and U.S. withholding
   9. Technical corrections to statute of limitations
2. Reevaluating a U.S. company’s foreign transactions, based on new law
3. Necessary refinements of tax planning that involves foreign structures and business transactions

Benefits

The panel will get to the bottom line of these and other key topics:

• The various new restrictions on the use of foreign tax credits.
• The new prohibition on reducing a foreign subsidiary's earnings and profits in certain Sect. 304 redemptions.
• The toughening of the rules on allocating and apportioning interest expense from a foreign corporation.
• The repeal of the 80/20 rules for foreign-source interest and the withholding exemption on dividends.

Upon completion of this webinar, you will have a firm grasp of the technical terms and taxpayer implications of the new restrictions on usage of foreign tax credits, and be better-positioned to work with clients on adjusting their compliance and tax planning.

Webinar/Teleconference

Strafford webinars/teleconferences offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

NASBA CPE Sponsor

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.

CPE Credit

Strafford is a NASBA CPE sponsor and our live seminars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

CLE Credit

Strafford's live seminars qualify for CLE in every state that accredits webinars. They offer you a high quality, cost effective, and convenient CLE option, with no lost travel time or expenses.

More Details >

Our Guarantee

Strafford webinars and teleconferences are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10.