Mastering Foreign Tax Credits for Corporations and Individuals: Calculations, Carrybacks, Carryforwards and Limitations
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers and corporate tax professionals with a comprehensive guide to the mechanics of the foreign tax credit in a global tax environment, including the rules, requirements, limitations, and opportunities for carryback, carryover and recalculation.
Outline
- Foreign tax credit structure and flaws in the Equalization Systems
- Where FTC fits in the effort to mitigate double taxation on foreign income
- Eligible taxpayers/corporations
- Creditable income
- Paid or Accrued
- Deductions vs. Credits
- Decide between the two – cannot take both
- Election to take FTC
- Determining Year of Deduction or Credit (Year of payment or year of accrual)
- Redetermination events
- Relation-back doctrine
- Forward adjustment to E & P pools
- Section 909 – Credit Splitting
- Limitations, carrybacks, carryovers and recalculations
- Foreign Tax Credit Limit
- Carrybacks and Carryovers
- Foreign Tax Credit Baskets and “base differences” after December 31, 2006
- Passive
- General
- “Base differences”
- IRS Forms 1116 and 1118
- Practical guidance on completing Form 1118
- Mechanics
- Examples
- Effective steps for tax planning and FTC utilization
- When taking the deduction may be preferred over the FTC
- Multi-tiered corporations
- Source of Income and Allocation of Expense
Benefits
The panel will analyze and explain these and other relevant topics:
- Determining year of deduction or credit
- Impact of taxes paid in foreign currency
- Effective steps for tax planning and FTC utilization
- Recent legislation under IRC Section 909
- Understanding phase out 4 rules
Faculty

Morris N. Robinson, Esq., CPA, LL.M.
Managing Director
M. Robinson & Co.
Mr. Robinson is an experienced tax lawyer and CPA with over 30 years of tax-law experience. Mr. Robinson and his team... | Read More
Mr. Robinson is an experienced tax lawyer and CPA with over 30 years of tax-law experience. Mr. Robinson and his team solve complex financial and tax planning problems that lie at the intersection of taxes, law, finance and business. He focuses his practice on International Taxation and Multistate Taxation of businesses and individuals, including tax planning for the sale of businesses. He has handled highly complex tax issues under the IRS Offshore Voluntary Disclosure Program. Mr. Robinson is currently President of the New England Chapter of the American Academy of Attorney-CPAs (AAA-CPA).
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Alison N. Dougherty, J.D., LL.M.
Senior Manager
Aronson
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
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.
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