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IRS Foreign Tax Credit Regulations and Recent Guidance: Income-Sourcing Standard, Digital Service Taxes, FDII

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

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Conducted on Tuesday, September 12, 2023

Recorded event now available

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This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and issued guidance. The panel will discuss income-sourcing standards, the impact on digital services taxes, sourcing of inclusions under Sections 951, 951A, and 1293, and other critical issues.

Description

In 2022, the U.S. Treasury Department and the IRS released final regulations and guidance concerning determining allowable foreign tax credits, allocating those tax credits, income-sourcing standards, and clarification on other vital issues. These regulations and recent guidance are critical to foreign tax planning and compliance, requiring tax practitioners to align planning methods with the new rules.

The final regulations guide practitioners on many technical issues for applying for the foreign tax credit. The final rules provide clarity on critical issues. Others need further guidance, such as (1) ensuring that the modified income-sourcing standards align with taxpayer's current tax compliance and planning methods; (2) sourcing of inclusions under Sections 951, 951A, and 1293; and (3) rules for the allocation and apportionment of certain expenses and for assigning foreign income taxes to different income groups for various purposes.

These final regulations are critical to U.S. taxpayers applying the foreign tax credit and resolving foreign tax audits.

Listen as our panel discusses the final regulations and guidance for the foreign tax credit, tax planning for foreign income, the allocation of expenses, assigning foreign taxes to baskets and income groups, rules relating to FDII, sourcing of inclusions under Sections 951, 951A, and 1293, and other essential issues.

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Outline

  1. Key provisions of the IRS final FTC regulations and guidance
  2. Challenges in allocating and assigning foreign taxes to baskets and income groups
  3. Sourcing of inclusions under Sections 951, 951A, and 1293
  4. Pitfalls to avoid and effective tax planning tactics in light of final regulations

Benefits

The panel will review these and other key issues:

  • What are the critical provisions of the IRS final regulations impacting foreign tax planning?
  • What are the key provisions of IRS guidance?
  • What issues do the final regulations leave unresolved?
  • What are the challenges of allocating and assigning foreign taxes to baskets and income groups?
  • What are the issues associated with foreign tax redeterminations and methods to overcome them?
  • What are the issues associated with sourcing inclusions under Sections 951, 951A, and 1293?

Faculty

Acosta, Rolando
Rolando J. (RJ) Acosta
Senior Manager
Ernst & Young

Mr. Acosta is an international tax specialist focused on the cross-border activities of private companies, investors,...  |  Read More

Becker, Adam
Adam P. Becker
Senior Manager
Ernst & Young

Mr. Becker is an International tax senior manager coming from a legal background, currently based in Washington D.C....  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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