The foreign tax credit intends to reduce the double tax burden that would otherwise arise when foreign source income is taxed by both the United States and the foreign country from which the income is derived. Generally, only income taxes paid or accrued to a foreign country or a U.S. possession (also referred to as a U.S. territory), or taxes paid or accrued to a foreign country or U.S. possession in lieu of an income tax, will qualify for the foreign tax credit. This seminar will help you understand the mechanics of foreign tax credits, qualifications and limitations on credits, computing foreign/domestic losses and recent legislative changes.

This basic level seminar is for corporate tax executives, law firm and accounting firm professionals who advise clients on structuring cross border transactions and on international tax planning matters. There is no advance preparation or prerequisites for this group live seminar. Field of Study: Taxes. Earn Up to 7.5 CPE/CLE Credits

Tuesday, May 23, 2017

8:30 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, 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

10:30 AM Refreshment Break

10:45 AM The Foreign Tax Credit Limitation - Section 904 and Look-Through Rules under Section 904(d) (3) and (4)

  • Determine creditable foreign income taxes
  • Refresher on Sourcing
  • 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 Regulation

12:30 PM Networking Luncheon

1:15 PM Impact of Overall Foreign Losses, Separate Limitation Losses and Overall Domestic Losses 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

2:45 PM Refreshment Break

3:00 PM Recent Legislative Developments

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

4:30 PM Seminar Concludes

Conference Location

Networking Seminars Conference Room c/o Regus,
Two Allen Center, 1200 Smith Street, 16th Floor,
Houston, Texas, 77002

Hotel: Doubletree Hotel Houston Downtown, 400 Dallas St, Houston, TX 77002 Phone: (713) 759-0202