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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, May 29, 2025

  • schedule Time

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

  • timer Program Length
Credit Information
$347.00
CLE
CPE
ALL

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS foreign tax credit regulations and issued guidance. The panel will discuss income sourcing, foreign tax redeterminations and sourcing of inclusions under sections 951, 951A, and 1293. It will also address digital services taxes, rules relating to foreign-derived intangible income (FDII), and other critical issues.

Faculty

Olga R. Beloded
Partner
Curtis, Mallet-Prevost, Colt & Mosle LLP

Ms. Beloded advises domestic and foreign corporations and high net worth individuals on tax aspects arising in connection with cross-border transactions, mergers and acquisitions and public and private securities offerings. She also regularly advises governments and state owned entities on international tax issues in investor-state arbitration proceedings and other international disputes, particularly in the area of oil and gas.

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Kristin E. Konschnik
Partner
McLemore Konschnik LLP

Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and Connecticut). She enjoys learning about her clients’ circumstances and goals, and she works hard to make complex tax concepts more accessible so that clients are empowered to make informed decisions about what matters to them. Because Ms. Konschnik has practised in London for many years, she has significant experience helping clients navigate multiple tax systems. Her primary expertise is in working with owner-managed businesses in a cross-border context. Ms. Konschnik's clients include family-owned and closely-held businesses (and their owners), entrepreneurs, and private equity, real estate and venture capital fund principals. In addition to regular advisory work for her long-term clients, she frequently works with management teams in private equity buyout and roll-over transactions. 

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Description

The IRS continues its focus on foreign tax credit standards since issuing final regulations and guidance concerning determining allowable foreign tax credits, allocating those tax credits, income-sourcing standards, and clarification on other vital issues. These regulations and related 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. However, challenges remain.

Listen as our panel discusses the IRS regulations and related 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 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 regulations impacting foreign tax planning?
  • What are the key provisions of recent IRS guidance?
  • 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 issues are associated with foreign income taxes subject to Section 245A(d)?
  • What are some key provisions clarifying rules related to FDII?