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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Counsel

Allocations, Apportionment, Limitations Under Section 904(b)(4), Impact of GILTI, Carryover and Carryback Rules, Section 960

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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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.

Presented By

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.

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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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Credit Information

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

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, September 21, 2021

  • schedule

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

  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

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

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.

BARBRI 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

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .