Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Counsel
Allocations, Apportionment, Limitations Under Section 904(b)(4), Impact of GILTI, Carryover and Carryback Rules, Section 960
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional "buckets" of foreign income grouping, allocation and apportionment rules, limitations under Section 904(b)(4), carryover and carryback rules under Section 904(c), and transition tax implications.
Outline
- Foreign tax credit rules
- Determining and calculating FTC
- Section 904 limitations
- Income categories/buckets
- Carryover/carryback rules
- Rules for deemed taxes paid under Section 960
Benefits
The panel will discuss these and other key issues:
- Changes to FTC rules under the 2017 tax reform law
- Application of Section 904 limitations and income categories to the current tax year
- Treatment of GILTI under the FTC regulations in determining exemption of interest and expenses
- Deemed paid foreign taxes under Section 960
- FTC carryovers and carrybacks
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Michael Masciangelo, CPA
Tax Partner; International Tax Services Practice Leader
BDO USA
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S.... | Read More
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.
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