Essentials of Foreign Tax Credit Planning

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Essentials of Foreign Tax Credit Planning

695.00 895.00

October 17, 2017 - Regis, 1501 Broadway, New York, NY

Earn Up to 7.5 CPE/CLE Credits

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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 changesDownload Brochure

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.  (We need to apply for NYS MCLE for this Course)
Earn Up to 7.5 CPE/CLE Credits

Tuesday, October 17, 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

Gabe Taubenfeld, Senior Manager, Ernst & Young LLP, New York, NY
Isaiah Hunter, Senior Manager, Ernst & Young LLP, New York, NY

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

Matthew Jenner, Associate, Baker & McKenzie LLP, Washington, DC

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

Andrew Guberman, Senior Manager, Deloitte Tax LLP, New York, NY

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
    Trumps Tax Plan
  • Legislative Update

Caren Shein, Managing Director, KPMG LLP, Washington, DC

4:45 PM Seminar Concludes

Conference Location

Networking Seminars c/o Regus, 1501 Broadway, 12th Floor, Manhattan, New York, 10036-5601, United States. Phone: 1 646 571 2000

For Hotel Reservations please call us at 877-500-1510.  We have a block of rooms at the Crowne Plaza.

Speaker Biographies

Andrew Guberman has more than eight years of experience in public accounting.  Andrew has gained experience in serving both international and middle-market companies.  He has served as an international tax specialist on numerous clients and helped on attribution studies and provision calculations.  He has also gained extensive knowledge in Visual Basic for Applications (“VBA”), SQL, C#, and other programming languages.  Coupling his technology and tax technical knowledge has helped Andrew create tax and efficiency models to assist in automation surrounding certain tasks of tax calculations/scenario planning for acquisitions, dispositions, attribution studies, and provision calculations. Andrew holds a bachelor’s degree in accounting from the Rutgers College Business School. 

Isaiah Hunter is a member of Ernst & Young LLP’s International Tax Services practice. He advises multinational corporations and private equity investors on a variety of international tax matters related to cross-border transactions and general international tax planning. In particular, he has assisted clients with tax-effective financing structures, Subpart F planning, tax treaty analysis, PFIC questions, and inversion issues.  Isaiah received a B.A. in Economics and Political Science from American University and a J.D. from New York University School of Law.

Matthew Jenner is an associate in the Tax Practice Group of the Washington, DC office. He advises multinational companies on federal tax issues related to cross-border transactions. He also represents clients in domestic and international tax disputes. Mr. Jenner focuses his practice on matters relating to the US federal income taxation of corporations, with an emphasis on international tax planning. He advises multinational companies on domestic and international reorganizations and acquisitions, and foreign tax credit planning.  He advised clients on post-acquisition integration planning and implementation; on efficient tax structure for divestiture of one of its major businesses; on tax-efficient cash repatriation strategies and represented clients in cross-border mergers and acquisitions. He earned his J.D. cum laude from Indiana University - Maurer School of Law and his B.A. Economics and Italian cum laude, from the University of Notre Dame.

Sashka Koleva is a senior manager in KPMG’s Tax Controversy Services practice. Sashka advises clients on all aspects of their federal tax controversies, from examination through post-Appeals mediation, with an emphasis on domestic and international tax issues in the financial services industry. Prior to joining KPMG, Sashka was an attorney with the IRS Office of Chief Counsel, Large Business & International, advising IRS exam teams and the Office of Appeals on both domestic and international tax issues arising from the audits of large financial institutions, hedge funds, and insurance companies, such as investment tax credits, taxation of financial instruments, deferral and foreign tax credit planning, U.S. tax treaty issues, and Chapter 3 withholding. During her tenure with the IRS Office of Chief Counsel, she served as counsel to the Issue Management Team on Foreign Tax Credit Generators and was a member of the Steering Committee of the Foreign Tax Credit International Practice Network. She also served as U.S. Counsel to the Joint International Tax Shelter Information Centre (“JITSIC”). Sashka is admitted to practice in New York. She earned her LL.M. in taxation from New York University School of Law and her J.D. from The University of Texas at Austin.

Caren S. Shein is a Managing Director at KPMG LLP’s National Tax Office in Washington, DC. Ms. Shein advises clients on outbound and inbound international tax planning and compliance issues, including foreign tax credit, subpart F, expense allocation, and permanent establishment.  Her particular area of expertise is the foreign tax credit, and she regularly writes, speaks and teaches in this area. Caren is the author or co-author of numerous articles, including“Uncovering the Covered Asset Acquisition Rules,” The Tax Executive (Sept.-Oct. 2010), “Emergency Economic Stabilization Act of 2008 – Throwing a Rope to the Ailing Financial Industry Tightens the Noose on Big Oil,” Tax Management International Journal (February 2009), “Temporary Regulations Deny Foreign Tax Credits for Amounts Paid Pursuant to “Structured Passive Investment Arrangements”, Tax Management International Journal (October 2008), “New Temporary Regulations Under Section 905(c): A Big Improvement but Puzzling Issues Still Remain,” Tax Management Journal (May 2008), “The IRS Proposes a New Approach to Determine the Technical Taxpayer – Will it Work?,” Journal of Taxation of Global Transactions (Fall 2006), “Section 905(c) – The Missing Piece of the Foreign Tax Credit Puzzle”, Tax Management International Journal (January 2002), and “A Fresh View of Overall Foreign Losses and Consolidated Returns”, Tax Management International Journal (May 1999). Prior to joining KPMG, Ms. Shein was an attorney advisor at the Internal Revenue Service, Office of Associate Chief Counsel (International). There she worked on rulings, regulations and litigation, primarily relating to foreign tax credits.  Ms. Shein began her career as a law clerk to the Honorable B. John Williams, Jr., of the United States Tax Court. 

Gabriel Taubenfeld is a Senior Manager in Ernst & Young LLP’s International Tax Services practice. He advises multinational corporations and private equity investors on a variety of international tax matters related to cross-border transactions and general international tax planning.   Gabe has advised on numerous cross-border M&A transactions, financing and reorganizations, ranging in value between $10m and $23b across a broad range of industries. In this regard he is experienced in transaction structuring, tax modeling, due diligence and pre and post-transaction restructuring. Gabe also regularly assists both US and foreign multinational clients with all aspects of US international tax planning and compliance. In particular, he has assisted clients with foreign tax credit planning, tax-effective cash repatriation planning, Subpart F planning, tax treaty issues, US trade or business issues and effectively connected income.  Gabe received a B.A. in Accounting from the City University of New York at Queens College, a J.D. from Fordham University School of Law and an LL.M. in Taxation from New York University School of Law. He is a member of the Tax Section of the American Bar Association and is a certified public accountant in New York.