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.
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Why Lorman?
Over 37 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 37 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.
- AIPB 1.5
- This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
- Arizona CLE 1.5
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.5
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
- CT CLE 1.5
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
- RI CLE 1.5
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 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
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 37 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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