Section 861 Sourcing Rules: Income Classifications, Allocating and Apportioning Expenses, Calculating the FTC
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss the sourcing rules under IRC Section 861 and provide examples of applying these to income classes, allocating and apportioning expenses, and determining the availability of the foreign tax credit. Our panel of foreign tax veterans will provide scenarios that walk international tax practitioners through these complex calculations.
Outline
- U.S. sourced income under Section 861: introduction
- Foreign tax credits
- Sourcing rules
- Interest and dividends
- Personal services
- Rents and royalties
- Real property proceeds
- Overlap rules
- Allocation and apportionment of expenses
- Interest
- Research and development
- Income tax
- Stewardship
- Examples
Benefits
The panel will review these and other critical issues:
- Sourcing interest and dividend income under Section 861(a)
- The difference between allocating and apportioning expenses under IRC Section 861(b)
- Specific examples of the application of the Section 861 guidelines to the calculation of the available foreign tax credit
- Categorizing CFC income under Section 861
Faculty
Surbhi Bordia
Partner
Armanino Advisory
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax... | Read More
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax and international tax issues. She has assisted several clients on transaction tax related matters including but not limited to taxable and non-taxable U.S. and cross-border reorganizations, liquidations, redemptions, spin-offs, dispositions, debt restructurings, due diligence projects and in application of consolidated return regulations. Ms. Bordia has hands on experience in international tax restructuring, IP migration planning, legal entity rationalizations and integrations post mergers and acquisitions. Her areas of expertise include but is not limited to GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credit, subpart F, withholding tax, investment in US property, FX gains and losses, treaty related issues, outbound transfers, permanent establishment and profit attribution rules etc. Before joining Armanino, Ms. Bordia worked at PwC, KPMG and Deloitte. She received her MBA at Haas School of Business at UC Berkeley, International Tax Certificate from Golden Gate University, Masters in Business and Bachelor of Commerce from Jai Narain Vyas University, India.
Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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Nick Zemil
Director
PwC
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on... | Read More
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on outbound transactions. Prior to joining PwC's Washington National Tax Services group, he was an associate at an international law firm where his practice focused on cross-border tax controversy issues ranging from the audit stage through litigation. While attending the University of Virginia School of Law, Mr. Zemil was on the editorial board of and was a contributor to the Virginia Tax Review.
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