Foreign Tax Credits for U.S. Taxpayers: Dealing With New Restrictions
Preparing for Tough Limits on Credit Use and Repeal of 80/20 Rules
New federal act credit provisions take effect in August and January
Recording of a 110-minute CPE/CLE webinar with Q&A
This CLE course will prepare you to promptly comply with the foreign tax credit and international tax reform aspects of the Education Jobs and Medicaid Assistance Act of 2010.
Outline
- International tax increases included in Education Jobs and Medicaid Assistance Act of 2010
- International tax extenders shifted from separate tax extender bill onto this legislation
- Prohibition against foreign tax credit-splitting
- Denial of foreign tax credits for disqualified portion of foreign tax paid on covered asset acquisition
- Separate foreign tax credit limitation on tax treaty items
- Limit on foreign taxes a U.S. shareholder is deemed to pay under Sect. 956 inclusions
- Prevention of reduction of foreign subsidiary’s earnings and profits in some Sect. 304 redemptions
- Tightening of affiliation rules for interest expense
- Repeal of 80/20 rules for interest paid and U.S. withholding
- Technical corrections to statute of limitations
- Reevaluating a U.S. company’s foreign transactions, based on new law
- Necessary refinements of tax planning that involves foreign structures and business transactions
Benefits
The panel will get to the bottom line of these and other key topics:
- The various new restrictions on the use of foreign tax credits.
- The new prohibition on reducing a foreign subsidiary's earnings and profits in certain Sect. 304 redemptions.
- The toughening of the rules on allocating and apportioning interest expense from a foreign corporation.
- The repeal of the 80/20 rules for foreign-source interest and the withholding exemption on dividends.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Fred Corso
Tax Director
Marcum
He also leads the firm's International Tax Services Group and has more than 14 years of experience in accounting firm... | Read More
He also leads the firm's International Tax Services Group and has more than 14 years of experience in accounting firm practice. He primarily works with high-tech, software, life sciences, manufacturing, professional service and import/distribution companies on cross-border tax matters.
CloseAllen Littman
Partner
Baker Hostetler
He specializes in international tax planning for U.S. and foreign-based companies. Before coming to the firm, he worked... | Read More
He specializes in international tax planning for U.S. and foreign-based companies. Before coming to the firm, he worked for more than five years as legislation counsel to the congressional Joint Committee on Taxation and as director of international tax at MCI.
CloseLaVonda Napka
Thompson Hine
Her work on clients' international tax projects covers transfer pricing, cross-border tax, withholding and CFC... | Read More
Her work on clients' international tax projects covers transfer pricing, cross-border tax, withholding and CFC analyses, among other topics.
CloseStephen Feldman
Partner
Morrison & Foerster
His general tax practice is primarily transaction-based and emphasizes outbound investments by U.S. companies and... | Read More
His general tax practice is primarily transaction-based and emphasizes outbound investments by U.S. companies and foreign investments in the U.S., among other matters. Before coming to the firm, he served as tax counsel at Bank of America.
CloseWilliam Winter
Tax Partner
Morris Manning & Martin
He specializes in both foreign taxation matters for expanding U.S. companies and U.S. taxation of foreign companies.... | Read More
He specializes in both foreign taxation matters for expanding U.S. companies and U.S. taxation of foreign companies. Before going into law practice, he was an international tax advisor with PricewaterhouseCoopers.
Close