Foreign Tax Credits Publication

FTC copy.jpg
FTC copy.jpg

Foreign Tax Credits Publication

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Foreign Tax Credits                                                                 

Seminar Publication Table of Contents:

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

  • Introduction
  • Creditability of Foreign Income Taxes
  • Foreign Tax Credit Baskets and Limitation Calculation
  • Indirect Credits
  • Related Party Look-Through Rules
  • Foreign Tax Redeterminations

The Foreign Tax Credit Limitation - Section 904 and 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, andPFIC inclusions
  • Look-Through Applied to Non-Controlled Section 902 Corporations: 
  • Section 904(d)(4) and Regulations

Foreign Source Losses and Overall Domestic Losses and their effect on the Foreign Tax Credit Limitation

  • Background of loss provisions
  • Loss computation steps
  • Overall foreign loss (“OFL”) recapture
  • Separate limitation loss (“SLL”) recapture
  • Overall domestic loss (“ODL”) recapture
  • Case study

Recent Legislative Developments

  • Regulatory Update
  • Section 909 Final Regulations
  • Section 901(m) – Notice 2014-44
  • Legislative Update
  • Extenders
  • Obama Administration Budget Proposals
  • International Update
  • BEPS