New Foreign Tax Credit and FTC Splitting Regulations

Mastering Section 909 and 901 Rules to Maximize Efficiencies in Complex FTC Planning

Recording of a 110-minute CPE/CLE webinar with Q&A


Conducted on Thursday, May 3, 2012

Recorded event now available

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Program Materials

This teleconference will provide tax professionals with a review of the temporary Sect. 909 and final Sect. 901 regulations involving foreign tax credits and foreign taxpayers. The panel will explore how the regs affect U.S. corporate taxpayers' compliance and planning in a variety of FTC structures.

Description

Corporate taxpayers and advisors involved with foreign business dealings must grasp all implications of Sect. 909 temporary regulations on foreign tax credit splitting events, and of Sect. 901 final regs governing who pays a foreign income tax for FTC purposes. The IRS and Treasury issued the rules in Feb. 2012.

Sect. 909 regs build upon IRS Notice 2010-92 and provide lists of FTC splitting events before and after 2011 tax years. The regs outline how to determine the amount of related income and taxes paid or accrued. Sect. 901 regs finalize a proposal issued in 2006 about who is legally liable for a foreign tax.

Intimate knowledge of these new rules, and what they do and don't change from earlier versions, is vital to fine-tuning tax planning for FTCs, complying with limits on using credits and foreign and domestic losses, properly handling covered asset acquisitions under Sect. 338, and other key matters.

Listen as our panel of experienced federal tax advisors analyzes the potential advantages and pitfalls in the new foreign tax credit splitting and foreign taxpayer rules.

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Outline

  1. Terms of Sect. 909 foreign tax credit splitter regs
    1. List of pre-2011 credit splitting events
    2. List of post-2011 credit splitting events
    3. Guidance on definition of "related income and split taxes"
    4. Changes to safe harbor rule for inter-branch payments
  2. Terms of Sect. 901 foreign taxpayer regulations
    1. Who legally is payer of a foreign tax?
    2. Taxes on combined income of two or more parties
    3. Allocation of taxes after change in partnership or disregarded entity ownership
  3. Key issues for taxpayers going forward
    1. Positive and negative developments with ability to split credits
      1. Planning for covered asset acquisitions under Sect. 338
    2. Limitations on foreign taxes
      1. Effects of foreign and domestic losses
      2. Consequences of recapture

Benefits

The panel will explore these and other important topics:

  • Provisions that promote and limit use of credit splitting.
  • Leveraging benefits of Sect. 338 elections.
  • Restrictions on who is considered a foreign taxpayer and how this can limit use of foreign and domestic losses.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Faculty

Peter Daub
Peter Daub

Partner
Baker & McKenzie

Mr. Daub has more than 20 years of experience in international and domestic tax planning for U.S. and foreign...  |  Read More

John D. Bates
John D. Bates

Atty
Ivins Phillips & Barker

He works primarily in international and corporate tax law on foreign tax credit matters, cross-border and domestic...  |  Read More

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