Description
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.
Date: 2020-02-05 Start Time: End Time:
Learning Objectives
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
Thomas R. Alvarez, CPA, MBT-BGBC Partners, LLP
