On-Demand


4.5 CPE

Overview of Foreign Tax Credit

On-Demand
4.5 CPE

Learning Objectives

Identify eligible foreign tax credits;Recognize the value of foreign tax credits;Apply key foreign tax concepts;Calculate foreign tax credit and limitation;Explain some of the complexities with OFL, ODL;Identify foreign tax credit issues in client discussions;Understand purpose and approach of Section 861;Explain allocation/apportionment methods available for interest, R&E, and other relevant expenses;Calculate allocation of expenses under standard and alternative methods;Explain impact of branches and CFC netting rule on expense allocations and apportionment;Describe the operation of the section 909 rules;Identify when the section 909 rules apply;Show applicability and impact of section 901(m) and relationship to section 338 elections

Major Topics

Summary of the FTC rules;Sections 901, 902, and 960; Separate Basket FTC Limitations and Look-Through Rules, Separate Limitation Losses;Overall Foreign Loss (OFL);Overall Domestic Loss (ODL);Indirect credit and lower tier subsidiaries;Review of Section 861 rules;Alternative allocation methods available;CFC netting rules;Tax book value methods;Impact of branches on expense allocations;Cover splitter structures and impact on FTC;Impact from 901(m)

CPE Credits Available

4.5 CPE
4.5
Taxes

Things to Know About This Course

Course Level

  • Basic

Professional Area of Focus

  • Tax
  • Taxation

Prerequisites

None

Advanced Preparation

None

Provider

AICPA

Purchase This Course

  • MACPA Member

    $ 99 99
    Join
  • MACPA Non-Member

    $ 129 129
    Your Price

Please login to register.