Section 861 Sourcing Rules: Income Classifications, Allocating and Apportioning Expenses, Calculating the FTC
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss the sourcing rules under IRC Section 861 and provide examples of applying these to income classes, allocating and apportioning expenses, and determining the availability of the foreign tax credit. Our panel of foreign tax veterans will provide scenarios that walk international tax practitioners through these complex calculations.
Outline
- U.S. sourced income under Section 861: introduction
- Foreign tax credits
- Sourcing rules
- Interest and dividends
- Personal services
- Rents and royalties
- Real property proceeds
- Overlap rules
- Allocation and apportionment of expenses
- Interest
- Research and development
- Income tax
- Stewardship
- Examples
Benefits
The panel will review these and other critical issues:
- Sourcing interest and dividend income under Section 861(a)
- The difference between allocating and apportioning expenses under IRC Section 861(b)
- Specific examples of the application of the Section 861 guidelines to the calculation of the available foreign tax credit
- Categorizing CFC income under Section 861
Faculty
Surbhi Bordia
Partner
Armanino
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
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Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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Nick Zemil
Director
PwC
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on... | Read More
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on outbound transactions. Prior to joining PwC's Washington National Tax Services group, he was an associate at an international law firm where his practice focused on cross-border tax controversy issues ranging from the audit stage through litigation. While attending the University of Virginia School of Law, Mr. Zemil was on the editorial board of and was a contributor to the Virginia Tax Review.
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