Foreign Tax Credits for U.S. Taxpayers: Dealing With New Restrictions

Outline

1. International tax increases included in Education Jobs and Medicaid Assistance Act of 2010
   1. International tax extenders shifted from separate tax extender bill onto this legislation
   2. Prohibition against foreign tax credit-splitting
   3. Denial of foreign tax credits for disqualified portion of foreign tax paid on covered asset acquisition
   4. Separate foreign tax credit limitation on tax treaty items
   5. Limit on foreign taxes a U.S. shareholder is deemed to pay under Sect. 956 inclusions
   6. Prevention of reduction of foreign subsidiary’s earnings and profits in some Sect. 304 redemptions
   7. Tightening of affiliation rules for interest expense
   8. Repeal of 80/20 rules for interest paid and U.S. withholding
   9. Technical corrections to statute of limitations
2. Reevaluating a U.S. company’s foreign transactions, based on new law
3. 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.