Foreign Tax Credit Baskets: OBBBA’s Impact on FTC Calculations
Categorizing Income, Allocating and Apportioning Expenses
A live 110-minute CPE webinar with interactive Q&A
This webinar will take an in-depth look at the categories of income reported on Form 1118 for the foreign tax credit (FTC). Our knowledgeable panel will explain how these baskets influence the ultimate calculation of the FTC, the allocation and apportionment of expenses by category, carryovers and carrybacks, and the impact of OBBBA on these baskets.
Outline
- Foreign tax credit baskets
- 951A—GILTI
- Foreign branch
- Passive
- General
- 901(j)
- Income resourced by treaty
- OBBBA legislation
- Allocating and apportioning expenses
- Planning to maximize FTCs
Benefits
The panel will cover these and other critical issues:
- Income allocation planning to preserve FTCs
- The impact of OBBBA on FTC calculations
- Allocating and apportioning expenses by branch
- Reporting income resourced by treaty
Faculty
Wilson Brakefield
Senior Manager
BDO USA
Mr. Brakefield is a Senior Manager, International Tax at BDO USA. He has experience working with... | Read More
Mr. Brakefield is a Senior Manager, International Tax at BDO USA. He has experience working with international tax law and regulations, mergers and acquisitions, private equity, Subchapter C, and partnership taxation. Mr. Brakefield is a strong business development professional with an LLM focused in Taxation from New York University School of Law and a JD/MBA from the University of Richmond.
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Neil Feinstein
Managing Director, National Tax Office, International Tax Service
BDO USA
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on... | Read More
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on domestic and international mergers and acquisitions and other business transactions, structuring of international operations (including tax efficient supply chains), financial products, and foreign currency transactions, as well as on other tax matters. His clients have included companies in the manufacturing, pharmaceuticals, specialty chemicals, and financial services industries, among other industries. Mr. Feinstein joined BDO in November 2022 after retiring as a managing director from Deloitte Tax LLP in 2020. Prior to joining Deloitte in 1996, he was partner in the law firm of Duane, Morris & Heckscher and in the law firm of Zapruder & Odell. Mr. Feinstein began his career as a tax associate at the law firm of Morgan, Lewis & Bockius.
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Michael Masciangelo, CPA
Tax Partner, International Tax Services Practice Leader
BDO USA
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S.... | Read More
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.
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CPE processing must be ordered prior to the event.
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