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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.

Runtime: 96 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of the Tax Reform and Jobs Act (TCJA) Impact on the Foreign Tax Credit Regime

  • Dividend Received Deduction Under Section 245A
  • New Foreign Tax Credit Limitation Categories
  • Repeal of Section 902 Indirect Foreign Tax Credit
  • GILTI Section 951Aand Partial Relief on Allocation of Expenses
  • Regulatory Update - Proposed and Final Regulations
  • Allocation and Apportionment of Deductions

Allocation and Apportionment of Deductions

  • Amendments to Pre-TCJA 861 Regulations
  • New Rules Relating to 864(e) and 904
  • New Adjustments Under 904(b)(4) for the Section 245A Deduction
  • Treatment of Exempt Income and Exempt Assets Under 864(e)(3) Relating to GILTI Income Offset by the Section 250 Deduction
  • Dividends Reduced by 245A Deduction Not Subject to Exempt Asset Rules of 864(e)(3)

Section 960 Deemed-Paid Credits

  • Computational and Grouping Rules
  • Allocation and Apportionment of Deductions for Section 960 Purposes
  • Section 960 and Section 956 Trap
  • Previously Taxed Earnings and Profits and Separate Annual Account Requirements
  • GILTI and Excess Limitation Accounts

Section 78 Gross-up Issues

  • Section 78 and GILTI Category Assignments

The New Foreign Branch Category Income

  • Adjustments to Branch Books and Records
  • Disregarded Transactions Between Branch and Owner and Other Related Parties

Anti-Abuse Rules

  • Loans by Direct or Indirect Partners to a Partnership
  • The High Tax Exception Rule and Integration Tax Regimes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on February 5, 2020.

Call 1-866-352-9540 for further credit information.

  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 406553
Published 2020
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