Foreign Tax Credit Utilization for Corporations: Calculations, Schedules and Considerations for Form 1118

Recording of a 110-minute CPE webinar with Q&A


Conducted on Thursday, April 30, 2015

Recorded event now available

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Program Materials

This webinar will prepare corporate tax advisors to handle complex calculations for reporting foreign-source income to claim foreign tax credits on Form 1118, including income classification baskets, carry-forwards and election decisions.

Description

Preparing Form 1118 to claim foreign tax credits on a corporate tax return presents numerous challenges for corporate tax professionals. The form requires separate calculations for each of the various income baskets, with each classification of income subject to different tax treatments, credit limitations and carryovers.

Corporate tax professionals must correctly calculate income or loss before adjustments, then make apportionment of allocable deductions for each type of income for which a foreign tax credit is being claimed. Additionally, there are specific rules in calculating income passed through from second- or lower-tier foreign corporations to the U.S. corporate taxpayer, which the corporate tax advisor must be able to navigate.

Listen as our panel of experienced corporate foreign tax experts provides detailed and practical tools for handling the complex schedules and calculations required to file Form 1118, including special circumstances for treaty-based filings, how to apportion R&D expenses, and reporting deemed taxes paid by lower-tier foreign corporations. The webinar will focus on the practical calculations needed to correctly file a Form 1118.

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Outline

  1. Foreign-source income baskets and determination of allocable income
  2. Allocation of deductions
  3. Eligible foreign taxes for credit
  4. Deemed taxes paid by lower-tier foreign corporations
  5. Redetermination of foreign tax
  6. Special treaty provisions

Benefits

The panel will explore these and other issues related to filing a Form 1118:

  • Calculating deemed dividends, using Section 78 gross-up provisions
  • Correctly allocating deductions, exclusions and NOLs
  • Determining eligible foreign taxes for credit
  • Deemed taxes paid by second-tier foreign corporations
  • How to handle and report redetermination of foreign tax

Faculty

Cory Perry
Cory Perry
Manager, International Tax Consulting
Grant Thornton

Mr. Perry focuses his practice on transactions and related cross-border issues for large multinational...  |  Read More

Misey, Robert
Robert J. Misey, Jr.

Shareholder
Reinhart Boerner Van Deuren

Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He...  |  Read More

Skinner, William
William R. Skinner

Partner
Fenwick & West

Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and...  |  Read More

David Weiner
David Weiner
International Tax Services Senior Manager
Grant Thornton

Mr. Weiner has over 10 years of experience at large law firms and accounting firms advising on tax aspects of...  |  Read More

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