Section 861 Sourcing Rules: Income Classifications, Allocating and Apportioning Expenses, Calculating the FTC
A live 110-minute CPE webinar with interactive 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
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
CloseWilliam R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
CloseEarly Discount (through 05/03/24)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
See
NASBA details.
Cannot Attend May 31?
Early Discount (through 05/03/24)
CPE credit is not available on downloads.
CPE On-Demand