IRS Foreign Tax Credit Regulations and Recent Guidance: New Income-Sourcing Standard, Digital Service Taxes, FDII
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and recently issued guidance. The panel will discuss new income-sourcing standards, the impact on digital services taxes, rules relating to foreign-derived intangible income (FDII), determination of foreign income taxes subject to the provisions of Section 245A(d), sourcing of inclusions under Sections 951, 951A, and 1293, and other critical issues.
Outline
- Key provisions of the IRS final FTC regulations and guidance
- Challenges in allocating and assigning foreign taxes to baskets and income groups
- Sourcing of inclusions under Sections 951, 951A, and 1293
- FDII rules and clarifications from recent FTC guidance
- Applicability of Section 245A(d)
- Pitfalls to avoid and effective tax planning tactics in light of final regulations
Benefits
The panel will review these and other key issues:
- What are the critical provisions of the IRS final regulations impacting foreign tax planning?
- What are the key provisions of recent IRS guidance?
- What are the key provisions clarifying rules relating to FDII?
- What issues do the final regulations leave unresolved?
- What are the challenges of allocating and assigning foreign taxes to baskets and income groups?
- What are the issues associated with foreign tax redeterminations and methods to overcome them?
- What are the issues associated with sourcing inclusions under Sections 951, 951A, and 1293?
- What are the issues associated with foreign income taxes subject to Section 245A(d)?
Faculty

Rolando J. (RJ) Acosta
Senior Manager
Ernst & Young
Mr. Acosta is an international tax specialist focused on the cross-border activities of private companies, investors,... | Read More
Mr. Acosta is an international tax specialist focused on the cross-border activities of private companies, investors, and family offices.
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Layla J. Asali
Member
Miller & Chevalier
Ms. Asali practices in a broad range of federal income tax matters, including domestic and cross-border corporate... | Read More
Ms. Asali practices in a broad range of federal income tax matters, including domestic and cross-border corporate acquisitions, dispositions and reorganizations; cross-border financings; joint venture planning; inbound and outbound transfers of intangible and other property; foreign tax credit utilization; and Subpart F planning. She counsels clients with respect to U.S. tax aspects of multinational structures and cross-border business operations, including supply chain planning, funding arrangements and cash management (including repatriation). She frequently speaks and writes on a variety of international and corporate tax topics.
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Michael Masciangelo
Senior Client Executive
BDO USA
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S.... | Read More
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.
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