Navigating Corporate AMT and International Tax Issues: New IRS Guidance, Calculating Corporate AMT, Foreign Tax Credit
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers guidance on the tax implications of the Corporate Alternative Minimum Tax (AMT) regime for inbound and outbound taxpayers. The panel will discuss the international tax implications of the corporate AMT, the scope and application of the tax, Notice 2024-10, Notice 2023-64 and Notice 2023-7, guidance regarding covered CFC distributions, and calculating adjusted financial statement income (AFSI) and the corporate AMT foreign tax credit.
Outline
- Entities subject to the corporate AMT
- Notice 2023-7, Notice 2023-20, and Notice 2023-64
- New interim guidance under Notice 2024-10
- Calculating corporate AMT
- Exceptions
- Tax planning considerations
Benefits
The panel will discuss these and other key issues:
- Impact of the corporate AMT
- Issues for foreign-owned U.S. corporations
- Key items under Notice 2023-7, Notice 2023-20, and Notice 2023-64
- Impact of interim guidance under Notice 2024-10 and next steps for taxpayers
- Calculating AFSI and the corporate AMT foreign tax credits
- Exceptions to the application of corporate AMT
Faculty
Einav Axler
Attorney
Fenwick & West
Ms. Axler advises on a broad variety of domestic and international tax matters. Prior to joining Fenwick, she was... | Read More
Ms. Axler advises on a broad variety of domestic and international tax matters. Prior to joining Fenwick, she was an associate in an Israeli office of one of the big-four accounting firms where she advised on international tax considerations for multinational clients.
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Danielle Marr
Attorney
Haynes Boone
Ms. Marr is a counsel in the Tax Practice Group in Haynes Boone’s Dallas office. Her practice focuses on... | Read More
Ms. Marr is a counsel in the Tax Practice Group in Haynes Boone’s Dallas office. Her practice focuses on federal income tax aspects of business transactions, including taxable and tax-free mergers and acquisitions, partnership formations, joint ventures, corporate reorganizations, public and private offerings, and real estate acquisitions and dispositions. Ms. Marr provides tax planning and structuring advice for a variety of clients involved in a broad range of industries, including limited liability companies, partnerships, private and publicly held corporations, financial institutions, REITs, and other business entities, as well as individuals. She regularly advises private equity funds and their portfolio companies, as well as investors, rollover sellers and management teams. Ms. Marr has extensive experience negotiating and drafting complex tax provisions in purchase agreements, partnership and LLC agreements, credit agreements, and escrow arrangements. She also provides tax planning and advice relating to ongoing governance and operations following a client’s initial formation or significant business transaction.
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Cannot Attend January 6?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.