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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, July 18, 2023

  • 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 webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and recent guidance. The panel will discuss income-sourcing standards, the impact on digital services taxes, rules relating to foreign-derived intangible income (FDII), determination of foreign income taxes subject to the provisions of Section 245A(d), sourcing of inclusions under Sections 951, 951A, and 1293, and other critical issues.

Faculty

Neil Feinstein
Managing Director, National Tax Office, International Tax Service
BDO USA

Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on domestic and international mergers and acquisitions and other business transactions, structuring of international operations (including tax efficient supply chains), financial products, and foreign currency transactions, as well as on other tax matters. His clients have included companies in the manufacturing, pharmaceuticals, specialty chemicals, and financial services industries, among other industries. Mr. Feinstein joined BDO in November 2022 after retiring as a managing director from Deloitte Tax LLP in 2020. Prior to joining Deloitte in 1996, he was partner in the law firm of Duane, Morris & Heckscher and in the law firm of Zapruder & Odell. Mr. Feinstein began his career as a tax associate at the law firm of Morgan, Lewis & Bockius.

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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.

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Patrick Carew
Managing Director
BDO USA

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Description

The IRS final regulations and guidance for foreign tax credits provide details on determining allowable foreign tax credits, allocating those tax credits, income-sourcing standards, and clarification on other vital issues. These regulations and guidance are critical to foreign tax planning and compliance, requiring tax practitioners to align planning methods with the new rules.

The final regulations guide practitioners on many technical issues for applying for the foreign tax credit. The final rules provide clarity on critical issues. Others need further guidance, such as (1) ensuring that the newly modified income-sourcing standards align with taxpayer's current tax compliance and planning methods, (2) rules relating to FDII and how these new regulations are applied, (3) determination of foreign income taxes subject to the provisions of Section 245A(d), (4) sourcing of inclusions under Sections 951, 951A, and 129, and (5) rules for the allocation and apportionment of certain expenses and for assigning foreign income taxes to different income groups for various purposes.

These final regulations are critical to U.S. taxpayers applying for the foreign tax credit and resolving foreign tax audits.

Listen as our panel discusses the final regulations and recent guidance for the foreign tax credit, tax planning for foreign income, the allocation of expenses, assigning foreign taxes to baskets and income groups, rules relating to FDII, sourcing of inclusions under Sections 951, 951A, and 1293, and other essential issues.

Outline

  1. Key provisions of the IRS final FTC regulations and guidance
  2. Challenges in allocating and assigning foreign taxes to baskets and income groups
  3. Sourcing of inclusions under Sections 951, 951A, and 1293
  4. FDII rules and clarifications from recent FTC guidance
  5. Applicability of Section 245A(d)
  6. Pitfalls to avoid and effective tax planning tactics in light of final regulations

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 are the key provisions of IRS guidance?
  • What are the key provisions clarifying rules relating to FDII?
  • 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 are the issues associated with sourcing inclusions under Sections 951, 951A, and 1293?
  • What are the issues associated with foreign income taxes subject to Section 245A(d)?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify changes to FTC rules under the IRS final regulations
  • Recognize the treatment of GILTI and FDII under the IRS final FTC regulations
  • Identify challenges in allocating and assigning foreign taxes to baskets and income groups
  • Recognize critical issues for sourcing of inclusions under Sections 951, 951A, and 1293

  • 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).