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    Networking Seminars Inc.

    445 Park Avenue, 9th Floor

    New York, NY 10022


    Get Social

    November 10, 2014 - NEW YORK, NY

    Networking Seminars announces its one-day technical seminar on Foreign Tax Credits. This seminar will review key issues in foreign tax credit planning and provide an update on recently passed legislation.  We will discuss in detail what qualifies for a credit, limitations on claiming the credit, determining the creditable tax, how to compute overall foreign and domestic losses and recent legislative updates on covered asset acquisitions and foreign tax credit splitter transactions.

    This seminar is for corporate tax, finance and accounting executives including tax managers, tax directors, tax specialists, controllers, CPAs, CFOs, as well as, corporate counsel and tax attorneys. There is no advance preparation or pre-requisites, for this basic level, group live seminar.

    Earn 7.5 CPE and 7.5/6.5 CLE Course Credits (50/60 minute State)

    MONDAY, NOVEMBER 10, 2014

    8:00 AM Registration and Continental Breakfast

    9:00 AM Overview of the Rules Affecting Foreign Tax Credits and Understanding the Foreign Tax Credit Mechanics: Sections 901, 902, 960 & 903

    • Overview of the rules affecting foreign tax credits
    • US taxing jurisdiction
    • Direct foreign tax credit – Section 901
    • Indirect foreign tax credit – Section 902
    • “In lieu of” taxes- Section 903
    • Special rules for FTCs – Section 960
    • Sourcing rules

    10:45 AM Refreshment Break

    11:00 AM The Foreign Tax Credit Limitation and Understanding the Look-Through Rules Under Section 904(d) (3) and (4) 

    • Determine creditable foreign income taxes
    • Compute FTC limitation by basket
    • Calculate lesser of creditable foreign income taxes or FTC limitation
    • For post-2006 years, taxpayers must compute a separate limitation for only two “baskets” of income
    • Sec. 904(a) FTC limitation
    • General Look-Through of Section 904(d)(3)
    • Section 78 Gross-up, Section 956 Inclusions, and  PFIC inclusions
    • Look-Through Applied to Non-Controlled Section 902 Corporations: 
      Section 904(d)(4) and Regulations

    12:30 PM  Networking Luncheon

    1:30 PM Foreign Source Losses and Overall Domestic Losses and their Effect on the Foreign Tax Credit Limitation

    • Indirect Credits: Section 902; Section 960; Deficits and Deemed Paid Taxes
    • OFLs. SLLs, and ODLs Foreign Tax Redeterminations

    3:15 PM Refreshment Break

    3:30 PM Recent Legislative Developments

    • Technical Taxpayer Regulations
    • Foreign Tax Credit Splitting Legislation and Regulations
    • Covered Asset Acquisition Legislation
    • Repeal of 956 Hopscotch Rules
    • Treaty Resourcing Basket
    • Green Book

    4:45 PM Question & Answers

    5:00 PM Seminar Concludes


    Executive Conference Center
    1601 Broadway, 8th Floor (at the corner of 48th Street)
    New York, NY 10019

    Hotel accommodations are at your discretion, we suggest:
    Crowne Plaza Manhattan
    1605 Broadway
    New York, NY 10019
    main (212) 977-4000


    Fill in the Form Below and Submit
    Register by phone by calling: 877 500 1510

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    Foreign Tax Credits/CFCs & Subpart F Income

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