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Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Counsel

Allocations, Apportionment, Limitations Under Section 904(b)(4), Impact of GILTI, Carryover and Carryback Rules, Section 960

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

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Conducted on Tuesday, September 21, 2021

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional "buckets" of foreign income grouping, allocation and apportionment rules, limitations under Section 904(b)(4), carryover and carryback rules under Section 904(c), and transition tax implications.


The IRS issued a set of regulations on FTCs outlining the impact of the 2017 tax reform law. The regulations address changes to the FTC rules in determining available credits and the application of GILTI in calculating FTCs. Tax counsel must be aware of the implications to taxpayers.

The most significant changes in the 2017 tax reform law related to the FTC provisions of the Code were modifications to the deemed paid foreign tax provisions under Section 960 and additional income categories and limitation provisions under Section 904. In addition, a discussion on the apportionment of interest expenses, which modifies existing Section 861 principles, was also addressed.

Tax counsel must recognize the urgency of grasping key concepts and applicability of the FTC rules in light of the regulations and implement tax planning techniques to benefit taxpayers.

Listen as our experienced panel provides a critical analysis of the practical implications of the FTC rules and key tax planning and best practices for taxpayers and tax counsel.



  1. Foreign tax credit rules
  2. Determining and calculating FTC
  3. Section 904 limitations
  4. Income categories/buckets
  5. Carryover/carryback rules
  6. Rules for deemed taxes paid under Section 960


The panel will discuss these and other key issues:

  • Changes to FTC rules under the 2017 tax reform law
  • Application of Section 904 limitations and income categories to the current tax year
  • Treatment of GILTI under the FTC regulations in determining exemption of interest and expenses
  • Deemed paid foreign taxes under Section 960
  • FTC carryovers and carrybacks


Diosdi, Anthony
Anthony V. Diosdi

Diosdi Ching & Liu

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax...  |  Read More

Masciangelo, Michael
Michael Masciangelo, CPA

Tax Partner; International Tax Services Practice Leader

Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S....  |  Read More

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