Guidance for Tax Counsel and New IRS Regulations: Foreign Tax Credit Limitations Under Section 904

Neel Modha, International Tax Principal
August 23, 2019

In this practical webinar, you will learn about:

  • How to calculate the foreign tax credit
  • The different baskets of the foreign tax credit
  • The changes in the foreign tax credit rules set forth in the 2017 Tax Cuts and Jobs Act

Upon course completion, you will be able to:

  • Describe the foreign tax credit limitation
  • Differentiate between a credit and a deduction
  • Identify the sourcing rules to source gross income
  • Outline the basic rules for allocating expenses
  • Identify the baskets used in the FTC analysis, including the new GILTI and Foreign Branch Income Baskets
  • Identify the documentation necessary to claim the foreign tax credit
  • Describe the carryforward and carryback rules, including transition rules from the TCJA
  • Examine deemed paid foreign taxes under IRC section 960

To register, click on the following link:


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