Foreign Tax Credits for Individuals: Form 1116 Changes, Final and Proposed Regulations
GILTI High-Tax Exception, Limitations and Calculations, Income Baskets, Carryovers
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recently released regulations and considering the addition of the new Schedules K-2 and K3 for pass-through entities. The panel will outline which foreign taxes are eligible for foreign income tax credits after GILTI, discuss strategies for determining the optimal treatment of creditable foreign taxes, and describe the elections available for taxpayers with foreign income and taxes.
Outline
- Section 901 creditable foreign taxes
- Proposed and final regulations
- Sourcing rules and grouping of income into baskets
- Income limitations
- Documentation and substantiation requirements and challenges
- Calculating credits and carryovers
- Preparing Form 1116
Benefits
The panel will discuss these and other important aspects of FTC calculations:
- Identifying creditable foreign taxes
- Basket groupings, foreign sourcing rules, and new income baskets
- Impact of GILTI on tax calculations
- Interest and other expense allocation
- Strategies for using up foreign tax credit carryovers
- Recently issued final and proposed regulations impacting FTCs
Faculty
Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on... | Read More
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.
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