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
This program is being postponed from 10-5-17 to a new date TBD
A live 110-minute CPE webinar with interactive Q&A
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.
- Identifying and calculating OFLs
- Identifying and calculating ODLs
- Using OFL and ODL offsets
- Subsequent year recaptures of offset amounts
- HTKO rules and calculations
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?
Dianne C. Mehany
Caplin & Drysdale
Ms. Mehany's practice focuses on international tax planning and controversies, including inbound and outbound tax... | Read More
Ms. Mehany's practice focuses on international tax planning and controversies, including inbound and outbound tax planning, foreign tax credits, tax treaties, tax audits, and FATCA planning and compliance. She also has experience in tax compliance of individuals, companies and financial institutions in the cross-border context, including FATCA reporting, reporting of interests in foreign trusts, and offshore financial accounts and assets.Close
C. Edward Kennedy, Jr., CPA, JD
Brady Ware & Company
Mr. Kennedy has more than 34 years of experience dealing with a variety of international tax matters, specializing... | Read More
Mr. Kennedy has more than 34 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Prior to joining the firm, he served as KPMG LLP's US firm lead for international social security matters.Close
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