Foreign Tax Credits: Applying Final Regulations, Categorizing Income, and Preparing Form 1118
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide an analysis of the final regulations issued in December 2021 and discuss the preparation of Form 1118 for tax practitioners and advisers grappling with these calculations.
Outline
- Foreign Tax Credit: introduction
- Recent changes
- 2017 Tax Act
- T.D. 9882, December 2019
- T.D. 9922, November 2020
- T.D. 9959, December 2021
- Preparing Form 1118, Foreign Tax Credit--Corporations
Benefits
The panel will cover these and other key issues:
- Applying the new attribution requirement to FTC calculations
- Allocating and apportioning research and experimentation expenditures
- Identifying Section 245A(d) and non-inclusion income
- Preparation of Form 1118, Foreign Tax Credit--Corporations
- Effective dates of regulation changes to FTC calculations
Faculty
Ariel Love
Attorney
Fenwick & West
Ms. Love focuses her practice on a broad variety of domestic and international tax planning and tax controversy... | Read More
Ms. Love focuses her practice on a broad variety of domestic and international tax planning and tax controversy matters. She regularly represents clients from a diverse set of industries and geographic areas, including a number of Fortune 500 companies.
CloseErika I. Stefanski, CPA, MST
Senior Director, International Tax
RSM US
Ms. Stefanski leads the firm’s foreign tax credit team. She has been servicing clients in the Great Lakes region... | Read More
Ms. Stefanski leads the firm’s foreign tax credit team. She has been servicing clients in the Great Lakes region since 2007. Ms. Stefanski focuses on providing international tax planning services, cross-border mergers and acquisitions due diligence, and oversees compliance services for middle market multinational manufacturing and wholesale distribution clients. In addition, she advises clients on complex international tax issues including planning related to global intangible low-taxed income (GILTI) and subpart F, foreign derived intangible income (FDII) and foreign tax credits.
CloseKenneth 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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