Foreign Tax Credit Baskets: Categorizing Income, Maximizing the FTC, Allocating and Apportioning Expenses
Recording of a 110-minute CPE webinar with Q&A
This webinar will take an in-depth look at the categories of income reported on Form 1118 for the foreign tax credit. Our knowledgeable panel will explain how these baskets influence the ultimate calculation of the foreign tax credit, the allocation and apportionment of expenses by category, carryovers and carrybacks, and the impact of recent legislation on these baskets.
Outline
- Foreign tax credit baskets
- 951A--GILTI
- Foreign branch
- Passive
- General
- 901(j)
- Income resourced by treaty
- Recent legislation
- Allocating and apportioning expenses
- Planning to maximize FTCs
Benefits
The panel will cover these and other critical issues:
- Income allocation planning to preserve foreign tax credits
- Identifying foreign branches and foreign branch income
- Allocating and apportioning expenses by branch
- Reporting income re-sourced by treaty
Faculty
Daphny Lazarus
Attorney
Fenwick & West
Ms. Lazarus regularly advises on a broad range of domestic and international tax matters, with an emphasis on the tax... | Read More
Ms. Lazarus regularly advises on a broad range of domestic and international tax matters, with an emphasis on the tax planning and transactional aspects of cross-border mergers and acquisitions, business formation, restructurings, joint ventures, inbound and outbound investments, and intellectual property.
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Alexis M. Maguina
Attorney
Fenwick & West
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and... | Read More
Mr. Maguina focuses his practice on a broad range of domestic and international tax matters, such as mergers and acquisitions, corporate restructurings, private equity funds and tax controversies.
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Kenneth Murwanto
Senior Manager, International Tax
RSM US
Mr. Murwanto leads the firm’s international tax practice in Orange County and the international tax reform... | Read More
Mr. Murwanto leads the firm’s international tax practice in Orange County and the international tax reform committee for the West region. He has 9 years of experience providing global tax planning and compliance services to U.S. and non-U.S. multinational businesses with cross-border business operations and investments. Mr. Murwanto regularly advises clients on complex international tax issues, including base erosion & anti-abuse tax (BEAT) mitigation, global intangible low-taxed income (GILTI) and subpart F planning, foreign-derived intangible income (FDII) optimization, foreign tax credit planning, supply chain management, funding & repatriation strategies, post-M&A integration, corporate inversions, and transfer pricing.
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