Foreign Tax Credit Limitations Under Section 904: New 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 webinar with Q&A
This webinar will guide tax counsel with a critical analysis of new IRS proposed guidance on foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the new regulations, additional "buckets" of foreign income grouping, new allocation and apportionment rules, limitations under Section 904(b)(4), carryover and carryback rules under Section 904(c), and transition tax implications.
Outline
- Foreign tax credit rules post-tax reform
- Determining and calculating FTC in light of 2017 tax reform law
- Section 904 new limitations
- New income categories/buckets
- Impact of newly proposed regulations on GILTI for FTC purposes
- Carryover/carryback rules
- Rules for deemed taxes paid under Section 960
Benefits
The panel will discuss these and other key issues:
- Changes to FTC rules under the 2017 tax reform law
- Application of new Section 904 limitations and income categories to the current tax year
- Treatment of GILTI under the IRS proposed FTC regulations in determining exemption of interest and expenses
- Deemed paid foreign taxes under Section 960
- FTC carryovers and carrybacks before and after tax reform
Faculty

Stanley Barsky
Principal
EisnerAmper
Mr. Barsky's practice involves a broad range of transactional and general advisory tax law matters, with a focus on... | Read More
Mr. Barsky's practice involves a broad range of transactional and general advisory tax law matters, with a focus on international tax issues. He represents clients in connection with taxable and tax-free M&A transactions, both in the domestic and cross-border contexts. He also advises U.S. businesses on establishing and expanding foreign operations as well as foreign nationals and businesses on establishing and expanding U.S. operations and investing in U.S. real estate. His practice also involves advising foreign nationals on restructuring their business and personal holdings in connection with becoming U.S. residents.
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Neel Modha
Senior Manager
Holthouse Carlin & Van Trigt
Mr. Modha's practice focuses on international tax, specializing in international tax consulting and compliance... | Read More
Mr. Modha's practice focuses on international tax, specializing in international tax consulting and compliance services. He works on a variety of international tax issues that affect individuals, corporations and partnerships.
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