Essentials of Foreign Tax Credit Planning

FTC NYC Dec copy.jpg
FTC NYC Dec copy.jpg

Essentials of Foreign Tax Credit Planning

795.00

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

Earn Up to 7.5 CPE/CLE Credits

Early Registration valid until Nov. 11, 2017.  Price will increase $200 after Nov. 11th. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

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

Tuesday, December 12, 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

Adam Brownstone, 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

Sashka Koleva, Senior Manager, 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.

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.

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.