Foreign Tax Credits for Individuals: Form 1116 Changes, Final Regulations, IRS Notice 2023-55
GILTI High-Tax Exception, Limitations and Calculations, Income Baskets, Carryovers
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
- IRS Notice 2023-55
- Sourcing rules and grouping of income into baskets
- Income limitations
- Documentation and substantiation requirements and challenges
- Calculating credits and carryovers
- Crossover between Form 1116 and Schedules K-2 and K-3
- 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
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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Maria (Masha) Zhandalinova, CPA
Tax Manager
The Wolf Group
Ms. Zhandalinova is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs,... | Read More
Ms. Zhandalinova is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs, high-net-worth individuals, and multinational businesses with their international tax planning and tax preparation needs. She regularly advises clients on proper reporting for their international businesses (whether inbound to or outbound from the US), proper reporting of global income and assets, and tax savings opportunities. Specific focus areas include reporting of Controlled Foreign Corporations (CFCs) and other foreign entities, entity basis calculations, Subpart F income and exceptions, Global Intangible Low-Taxed Income (GILTI), Earnings and Profits (E&P) calculations, §962 and other elections, Previously Taxed Earnings & Profits (PTEP) ordering and calculations, and foreign asset reporting.
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