Foreign Taxpayers and the CARES Act: NOL Carrybacks, PPP Loans, Permanent Establishment, FTCs
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will address the benefits available for foreign taxpayers under the CARES Act and the caveats of implementing this relief. Our international tax experts will explain the unique considerations of applying this relief to foreign individual and business taxpayers.
- Relief applicable to foreign and domestic taxpayers
- Deadline relief
- Foreign entities and loan relief
- NOL carrybacks
- 163(j) interest limitation changes
- Residency tests
- Permanent establishment
- Other issues for foreign taxpayers
The panel will review these and other critical considerations:
- How do specific countries determine residency?
- Which taxpayers might be affected by permanent establishment (PE) rules?
- What relief, if any, is anticipated for residency and PE status?
- When it may be best to forego an NOL carryback
- What caveats are there for carrybacks of NOLs with foreign tax credits?
- How does 163(j) relief impact foreign taxpayers?
Kyle Dawley, J.D., CPA
Principal, Global Tax Services
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses... | Read More
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses and individuals. Before CLA, he spent time in Big 4 accounting firms developing strategies and managing complex international business and tax projects which also included transfer pricing optomization. In addition to having expertise in international tax matters, Mr. Dawley has a deep appreciation of general business issues as he spent over a year employed in a biotech start-up company where he was tasked with running their daily operations and long-term vision. He has served clients in a wide-range of industries from both a U.S. inbound and outbound perspective.Close
Patrick J. McCormick, J.D., LL.M.
Culhane Meadows Haughian & Walsh
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close