Individual Foreign Tax Credit: Advanced-Level Calculations and Planning

Identifying OFL and ODL Situations, Calculating Losses for Offsets, Available Elections, and Avoiding Adverse HTKO Results

A live 110-minute CPE webinar with interactive Q&A


Thursday, October 5, 2017
(Alert: Event date has changed from 8/29/2017!)
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, September 8, 2017


This webinar will provide tax advisers with a thorough and practical guide to more advanced concepts in calculating and maximizing the benefits of foreign tax credits. The panel will go beyond the basics to discuss avoiding high-tax kickout (HTKO) treatment, using overall domestic loss (ODLs) and overall foreign loss (OFLs) to maximize foreign tax credit benefits and navigating OFL recapture and recharacterization rules. The webinar will feature concrete examples of the calculations and reporting of these advanced concepts.

Description

The complexities of the foreign tax credit rules can present significant challenges to tax advisers, even those who have significant experience in the mechanics of completing Form 1116. Overall foreign or domestic losses, as well as income from HTKO countries, can have significant impact on currently available foreign credits as well as carry-forward amounts.

For advisers to taxpayers in either foreign or domestic net loss positions, determining how to best utilize the Section 904 foreign tax credit can be particularly difficult. An OFL occurs when a taxpayer’s foreign deductions exceed foreign income. Taxpayers in an OFL position may use the OFL as a deduction to offset current U.S. source income; however, this may impact the treatment of subsequent foreign income once the loss has been eliminated.

Foreign tax credit calculations and planning become even more complicated when a taxpayer is in an ODL position. ODLs occur when a taxpayer’s domestic losses exceed net foreign income. Taxpayers with an ODL may use the loss to offset taxable foreign income; however, an ODL can only be created in a credit year, and subsequent year’s domestic income is subject to recapture as foreign-source. Tax advisers must understand the OFL and ODL rules to avoid costly tax mistakes.

Listen as our experienced panel goes beyond the basics to provide practical guidance to some of the most complex foreign tax credit calculations and considerations.

Outline

  1. Identifying and calculating OFLs
  2. Identifying and calculating ODLs
  3. Using OFL and ODL offsets
  4. Subsequent year recaptures of offset amounts
  5. HTKO rules and calculations

Benefits

The panel will discuss these and other important and complex topics:

  • Challenges in determining whether a taxpayer has an OFL or ODL
  • What is the impact of a prior year decision to deduct foreign taxes during an OFL year on claiming credits for indirect foreign taxes and repatriation of foreign-source income?
  • What do advisers serving clients in ODL situations who have used the ODL to offset foreign-source income need to know about subsequent year recapture of domestic income?
  • How do the grouping rules work in determining whether foreign-source income is “high-taxed” and subject to HTKO treatment?

Learning Objectives

After completing this course, you will be able to:

  • Determine how to calculate an OFL and an ODL
  • Recognize the impact of deduction of creditable foreign taxes in OFL situations
  • Identify the process for determining and calculating high-taxed foreign income subject to the HTKO rules
  • Reporting OFLs and ODLs on Form 1116

Faculty

Alison N. Dougherty, J.D., LL.M., Director
Aronson, Rockville, Md.

Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.

Additional faculty to be announced.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $97.00

Includes Early Discount Savings of $50.00 (through 09/08/17)

Live Webinar & CPE Processing $132.00

Includes Live Webinar Early Discount Savings of $50.00 (through 09/08/17)


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. This webinar assumes attendees already have a detailed working knowledge and understanding of foreign tax credits, Form 1116, elections available to foreign taxpayers for taxpayers with foreign income and taxes and sourcing rules; familiarity with 901 creditable foreign taxes and deemed paid taxes.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $97.00
Available 48 hours after the live event

Includes Early Discount Savings of $50.00 (through 09/08/17)

How does this work?

Recorded Audio Download (MP3) $97.00
Available 24 hours after the live event

Includes Early Discount Savings of $50.00 (through 09/08/17)

How does this work?

DVD (Slide Presentation with Audio) $97.00 plus $9.45 S&H
Available ten business days after the live event

Includes Early Discount Savings of $50.00 (through 09/08/17)

How does this work?


Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $144.00

Includes Special Savings of $150.00 (through 09/08/17)

Live Webinar & Audio Download $144.00

Includes Special Savings of $150.00 (through 09/08/17)

Live Webinar & DVD $144.00 plus $9.45 S&H

Includes Special Savings of $150.00 (through 09/08/17)


NASBA CPE Sponsor

National Registry of CPE Sponsors

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Early Registration
Discount Deadline
September 8, 2017

or call 1-800-926-7926

Can't Attend the Live Program?

CPE Credit

Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

or call 1-800-926-7926

EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

or call 1-800-926-7926

Customer Reviews

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

Matt Bristow

Cover & Rossiter

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

I purchased the conference a few minutes after it began and the customer service rep was very helpful and got me signed up and logged into the conference very quickly.

Joanna Johnston

Savas Greene & Company

The conference was technical, informative and presented at a good pace.

Krystal Ching

KMH

I loved the tools and handouts. Every CPE class should offer these kind of tools.

Jackie Meyer

Sample and Bailey

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.