New IRS Foreign Tax Credit Regulations: Allocating Expenses, Assigning Foreign Taxes to Income Groups, GILTI, NOLs
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes on baskets and income groups. The panel will also discuss proposed Sections 1.861-20 and 1.1502-4 in regards to assigning foreign taxes to different Section 904 income groups and potential pitfalls to avoid.
Outline
- Key provisions of the new IRS final FTC regulations
- Challenges in allocating and assigning foreign taxes to baskets and income groups
- Pitfalls to avoid and effective tax planning tactics in light of final regulations
- Additional proposed regulations
- Section 905(c); foreign tax redetermination
- Proposed Section 1.861-20; allocating and apportioning foreign income taxes
- Proposed Section 1.1502-4; consolidated foreign tax credit rules
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 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 is the impact of proposed Sections 1.861-20 and 1.1502-4?
Faculty
Melody C. Horton, CPA
Shareholder
Elliott Davis
Ms. Horton has more than nine years of experience in public accounting. She provides comprehensive planning and... | Read More
Ms. Horton has more than nine years of experience in public accounting. She provides comprehensive planning and compliance services to clients with multi-state and international operations across a variety of industries. Ms. Horton primarily works with clients that have international operations in the manufacturing, distribution, technology, and services industries. She assists many international companies making inbound investment in the US with tax structuring and economic incentives. Ms. Horton also works with international companies to create efficient global tax strategies. She has significant experience with income tax provisions and other ASC 740 reporting matters, international reporting requirements, foreign tax credit planning, repatriation of foreign profits, treaty analysis and thin capitalization rules.
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Michael Knobler
Attorney
Fenwick & West
Mr. Knobler focuses his practice on U.S. international and domestic tax planning, mergers and acquisitions, and... | Read More
Mr. Knobler focuses his practice on U.S. international and domestic tax planning, mergers and acquisitions, and controversies. His clients range from start-ups to multinational corporations.
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