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  • videocam Live Online with Live Q&A
  • calendar_month December 1, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Foreign Tax Credit Baskets: OBBBA’s Impact on FTC Calculations

Categorizing Income, Allocating and Apportioning Expenses

$197.00

This course is $0 with these passes:

CPE
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Description

The FTC should prevent double taxation on income already taxed by another country. The FTC can only be applied to foreign income within the same statutory category. Form 1118 contains many baskets for separating income:

  • 951A—GILTI
  • Foreign branch
  • Passive
  • General
  • 901(j)
  • Income resourced by treaty

Once income is distributed by basket, deductions must be allocated and apportioned to each category. 

OBBBA modifications require foreign taxpayers to revisit these complex calculations. The rate for the deemed paid foreign tax credit for NCTI/GILTI increased from 80% to 90%. The sourcing rule for inventory includes products produced in the U.S. and sold through a foreign branch. And the 163(j) interest limitation is again calculated on EBIT (earnings before interest and taxes), excluding depreciation and amortization deductions from the calculation, rather than EBITDA. Tax advisers need to understand the implications of these changes on FTC income and categories to maximize this credit.

Listen as our panel of international tax experts details the composition of each foreign income basket, OBBBA legislation affecting income and expenses classification, and how categorization affects the utilization of this valuable credit.

Presented By

Wilson Brakefield
Senior Manager
BDO USA
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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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).

Date + Time

  • event

    Monday, December 1, 2025

  • schedule

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

I. Foreign tax credit baskets

II. 951A—GILTI

III. Foreign branch

IV. Passive

V. General

VI. 901(j)

VII. Income resourced by treaty

VIII. OBBBA legislation

IX. Allocating and apportioning expenses

X. Planning to maximize FTCs

The panel will cover these and other critical issues:

  • Income allocation planning to preserve FTCs
  • The impact of OBBBA on FTC calculations
  • Allocating and apportioning expenses by branch
  • Reporting income resourced by treaty

Learning Objectives

After completing this course, you will be able to:

  • Understand the categories of income reported on Form 1118 for the FTC
  • Differentiate between allocating and apportioning expenses
  • Identify baskets of income
  • Ascertain how OBBBA affects FTC calculations
  • Recognize how the U.S. foreign tax reporting regime is structured
  • Establish interest and other expense allocations
  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.


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 .