IRS Foreign Tax Credit Regulations and Recent Guidance: Income-Sourcing Standard, Digital Service Taxes, FDII
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and recent guidance. The panel will discuss income-sourcing standards, the impact on digital services taxes, rules relating to foreign-derived intangible income (FDII), determination of foreign income taxes subject to the provisions of Section 245A(d), sourcing of inclusions under Sections 951, 951A, and 1293, and other critical issues.
Outline
- Key provisions of the IRS final FTC regulations and guidance
- Challenges in allocating and assigning foreign taxes to baskets and income groups
- Sourcing of inclusions under Sections 951, 951A, and 1293
- FDII rules and clarifications from recent FTC guidance
- Applicability of Section 245A(d)
- Pitfalls to avoid and effective tax planning tactics in light of final regulations
Benefits
The panel will review these and other key issues:
- What are the critical provisions of the IRS final regulations impacting foreign tax planning?
- What are the key provisions of IRS guidance?
- What are the key provisions clarifying rules relating to FDII?
- What issues do the final regulations leave unresolved?
- What are the challenges of allocating and assigning foreign taxes to baskets and income groups?
- What are the issues associated with foreign tax redeterminations and methods to overcome them?
- What are the issues associated with sourcing inclusions under Sections 951, 951A, and 1293?
- What are the issues associated with foreign income taxes subject to Section 245A(d)?
Faculty
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Neil Feinstein
Managing Director, National Tax Office, International Tax Service
BDO USA
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on... | Read More
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on domestic and international mergers and acquisitions and other business transactions, structuring of international operations (including tax efficient supply chains), financial products, and foreign currency transactions, as well as on other tax matters. His clients have included companies in the manufacturing, pharmaceuticals, specialty chemicals, and financial services industries, among other industries. Mr. Feinstein joined BDO in November 2022 after retiring as a managing director from Deloitte Tax LLP in 2020. Prior to joining Deloitte in 1996, he was partner in the law firm of Duane, Morris & Heckscher and in the law firm of Zapruder & Odell. Mr. Feinstein began his career as a tax associate at the law firm of Morgan, Lewis & Bockius.
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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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