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New Regulations on Foreign Tax Credit Limitations Under Section 904

 

Gain insight into changes to the new law as well as proposed and final regulations made to the foreign tax credit regime.

The Tax Cuts and Jobs Act (TCJA) continues to have a profound impact on both domestic and international tax planning and compliance. Taxpayers and their advisors need to understand how TCJA impacted the foreign tax credit regime. This topic will help you understand the overall changes the new law and proposed and final regulations made to the foreign tax credit regime, identify potential traps of those changes, provide an overall framework for modelling the impact to companies and individuals, and attain a working knowledge of the mechanics of the new rules.

Agenda

Faculty

Thomas R. Alvarez, CPA, MBT

Thomas R. Alvarez, CPA, MBT

BGBC Partners, LLP

  • Senior tax manager with BGBC Partners, LLP and serves as the international and domestic adviser for the firm
  • Has worked with high-profile, high net-worth entertainment individuals, Fortune 500 manufacturing, retailing and distribution companies, ex-patriates, foreign trusts, estate issues with foreign considerations, and sophisticated business clients with extensive international tax issues requiring frequent travel to foreign countries to instruct and update subsidiaries and local tax personnel on United States tax laws
  • Before joining BGBC Partners, spent several years as a senior tax manager in the Los Angeles office of a Big 4 accounting firm, served as a tax director for an international conglomerate, a senior tax advisor for a multinational Fortune 100 company
  • Experience representing his clients before the IRS and state and local taxing authorities and has frequently spoken on tax panels for various industry groups, and often serves as a lecturer for various continuing professional educational courses for accountants and attorneys
  • Has been published in leading tax journals
  • M.A. degree in business taxation, University of Southern California; B.S. degree, California State University, Sacramento

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