BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, September 21, 2021

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional "buckets" of foreign income grouping, allocation and apportionment rules, limitations under Section 904(b)(4), carryover and carryback rules under Section 904(c), and transition tax implications.

Faculty

Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Michael Masciangelo
Tax Partner; International Tax Services Practice Leader
BDO USA

Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

Description

The IRS issued a set of regulations on FTCs outlining the impact of the 2017 tax reform law. The regulations address changes to the FTC rules in determining available credits and the application of GILTI in calculating FTCs. Tax counsel must be aware of the implications to taxpayers.

The most significant changes in the 2017 tax reform law related to the FTC provisions of the Code were modifications to the deemed paid foreign tax provisions under Section 960 and additional income categories and limitation provisions under Section 904. In addition, a discussion on the apportionment of interest expenses, which modifies existing Section 861 principles, was also addressed.

Tax counsel must recognize the urgency of grasping key concepts and applicability of the FTC rules in light of the regulations and implement tax planning techniques to benefit taxpayers.

Listen as our experienced panel provides a critical analysis of the practical implications of the FTC rules and key tax planning and best practices for taxpayers and tax counsel.

Outline

  1. Foreign tax credit rules
  2. Determining and calculating FTC
  3. Section 904 limitations
  4. Income categories/buckets
  5. Carryover/carryback rules
  6. Rules for deemed taxes paid under Section 960

Benefits

The panel will discuss these and other key issues:

  • Changes to FTC rules under the 2017 tax reform law
  • Application of Section 904 limitations and income categories to the current tax year
  • Treatment of GILTI under the FTC regulations in determining exemption of interest and expenses
  • Deemed paid foreign taxes under Section 960
  • FTC carryovers and carrybacks

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify changes to FTC rules under the 2017 tax reform law
  • Understand the application of Section 904 limitations and income categories to the current tax year
  • Recognize the treatment of GILTI under the FTC regulations in determining exemption of interest and expenses
  • Determine FTC carryovers and carrybacks
  • Understand the application of deemed paid foreign taxes under Section 960

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Working knowledge and understanding of foreign tax credits, Form 1116, elections available to foreign taxpayers for taxpayers with foreign income and taxes and sourcing rules; familiarity with 901 creditable foreign taxes and deemed paid taxes.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).