BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, May 19, 2022

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recently released regulations and considering the addition of the new Schedules K-2 and K3 for pass-through entities. The panel will outline which foreign taxes are eligible for foreign income tax credits after GILTI, discuss strategies for determining the optimal treatment of creditable foreign taxes, and describe the elections available for taxpayers with foreign income and taxes.

Faculty

John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt LLP

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.

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Alison N. Dougherty
Managing Member
Googolplex Tax, LLC

Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign  trusts. 





Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.  

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Description

Recent legislation has made significant and far-reaching changes to taxpayers' ability to claim FTCs under Section 901. The basket classifications of foreign-based income have led to heightened complexity in the calculations and reporting required to claim the FTC on Form 1116.

U.S. taxpayers are entitled under Section 901 to claim FTCs for certain foreign income taxes, whether paid or deemed paid. However, the foreign tax credit rules are involved, the carryback and carryover periods are limited, and the availability of the credits is limited by the category or basket of income and by the ratio of foreign-source income to worldwide income.

In December 2021, Treasury finalized regulations (T.D. 9959) on the FTC and foreign-derived intangible income (FDII). These were generally similar to the proposed regulations with a few notable differences. In September 2020, T.D. 9922 was issued covering the FTC and expense allocations and even earlier, but still recently (July 2020), T.D. 9902 on the GILTI high tax exclusion (HTE) was published. Wading through and understanding these complex legislative changes is challenging for tax professionals.

Listen as our expert panel provides a comprehensive guide to calculating FTCs and completing Form 1116. The panel will outline which foreign taxes are eligible for Section 901 FTC and discuss the recent changes to Form 1116.

Outline

  1. Section 901 creditable foreign taxes
  2. Proposed and final regulations
  3. Sourcing rules and grouping of income into baskets
  4. Income limitations
  5. Documentation and substantiation requirements and challenges
  6. Calculating credits and carryovers
  7. Preparing Form 1116

Benefits

The panel will discuss these and other important aspects of FTC calculations:

  • Identifying creditable foreign taxes
  • Basket groupings, foreign sourcing rules, and new income baskets
  • Impact of GILTI on tax calculations
  • Interest and other expense allocation
  • Strategies for using up foreign tax credit carryovers
  • Recently issued final and proposed regulations impacting FTCs

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify creditable foreign taxes
  • Recognize deemed paid foreign taxes
  • Determine how to basket for purposes of computing the foreign tax credit
  • Establish the impact of GILTI on tax calculations
  • Ascertain the changes impacting new Form 1116

  • 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).