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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

    Thursday, April 16, 2020

  • 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.

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes on baskets and income groups. The panel will also discuss proposed Sections 1.861-20 and 1.1502-4 in regards to assigning foreign taxes to different Section 904 income groups and potential pitfalls to avoid.

Faculty

Melody C. Horton
Founder
Arc Advisors

Ms. Horton has spent her career in public accounting, specializing in working with clients with international activities. She provides comprehensive planning and compliance services to clients with multi-state and multinational operations across a variety of industries. Ms. Horton primarily works with clients that have international operations in the manufacturing, distribution, technology, and services industries. She assists many international companies making inbound investment in the US with tax structuring and economic incentives. Ms. Horton also works with international companies to create efficient global tax strategies, maximizing their FDII benefits and minimizing the GILTI and BEAT impact. She has significant experience with income tax provisions and other ASC 740 reporting matters, international reporting requirements, foreign tax credit planning, repatriation of foreign profits, treaty analysis and voluntary disclosure filings.

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Michael Knobler
Attorney
Fenwick & West LLP

Mr. Knobler focuses his practice on U.S. international and domestic tax planning, mergers and acquisitions, and controversies. His clients range from start-ups to multinational corporations.

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Description

On Dec. 2, 2019, the IRS issued final regulations concerning determining the amount of allowable foreign tax credits and allocating those tax credits. These regulations are critical to foreign tax planning and compliance, requiring tax practitioners to align any planning methods with the new rules.

The new regulations guide practitioners on many technical issues for applying the foreign tax credit. However, the new final rules failed to extend Section 904(d)(3) look-thru treatment to the GILTI basket or Section 960(b) treatment to foreign taxes imposed on disregarded distributions of previously taxed earnings and profits.

Also, the IRS issued: 1. final regulations related to the allocation and recapture of overall foreign losses and total domestic losses, 2. final and new proposed regs related to foreign tax redeterminations under Section 905(c), and 3. new rules for the allocation and apportionment of R&E and stewardship expenses, and for assigning foreign income taxes to different income groups for various purposes.

These final and new proposed regulations are critical to U.S. companies in applying the foreign tax credit and resolving foreign tax audits.

Listen as our panel discusses the final and new proposed regulations for the foreign tax credit, tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes to baskets and income groups.

Outline

  1. Key provisions of the new IRS final FTC regulations
  2. Challenges in allocating and assigning foreign taxes to baskets and income groups
  3. Pitfalls to avoid and effective tax planning tactics in light of final regulations
  4. Additional proposed regulations
    • Section 905(c); foreign tax redetermination
    • Proposed Section 1.861-20; allocating and apportioning foreign income taxes
    • Proposed Section 1.1502-4; consolidated foreign tax credit rules

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 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 is the impact of proposed Sections 1.861-20 and 1.1502-4?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify changes to FTC rules under the new IRS final regulations
  • Understand the application of new Section 904 limitations and income categories to the current tax year
  • Recognize the treatment of GILTI under the IRS proposed FTC regulations in determining exemption of interest and expenses
  • Identify challenges in allocating and assigning foreign taxes to baskets and income groups
  • Understand the application of deemed paid foreign taxes under Section 960
  • Ascertain the critical issues in foreign tax redetermination and proposed Sections1.861-20 and 1.1502-4

  • 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.