New Form 1116 Foreign Tax Credits for Individuals: New Income Baskets, New Calculation Rules
GILTI, Section 78 "Gross Ups," Repeal of Deemed Paid Foreign Tax, New Limitations and Calculation Rules
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recent IRS guidance interpreting the 2017 tax reform law changes to the Section 901 credit regime. The panel will outline which foreign taxes are eligible for foreign income tax credits after GILTI, discuss strategies for determining the optimal treatment of creditable foreign taxes, and describe the elections available for taxpayers with foreign income and taxes.
- Section 901 creditable foreign taxes
- Sourcing rules and grouping of income into "baskets"
- Income limitations
- Documentation and substantiation requirements and challenges
- Calculating credits and carryovers
- Changes to 2018 Form 1116
The panel will discuss these and other important aspects of FTC calculations:
- Identifying creditable foreign taxes
- "Basket" groupings, foreign sourcing rules and new income baskets
- Impact of GILTI on tax calculations
- Other key changes from the 2017 tax reform law reflected in Form 1116
- Interest and other expense allocation
- Strategies for using up foreign tax credit carryovers
Alison N. Dougherty, J.D., LL.M.
Director, Tax Services
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.Close
Holthouse Carlin & Van Trigt
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on... | Read More
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.Close
Other Formats— Anytime, Anywhere
CPE On-DemandSee NASBA details.