Cover the Foreign Tax Credit Rules and key concepts.
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)
