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New IRS Foreign Tax Credit Regulations: Allocating Expenses, Assigning Foreign Taxes to Income Groups, GILTI, NOLs

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This CLE/CPE webinar will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes on baskets and income groups. The panel will also discuss proposed Sections 1.861-20 and 1.1502-4 in regards to assigning foreign taxes to different Section 904 income groups and potential pitfalls to avoid.

Fenwick tax partner Will Skinner and his fellow panel will review these and other key issues:

  • What are the critical provisions of the IRS final regulations impacting foreign tax planning?
  • What issues do the final regulations leave unresolved?
  • What are the challenges of allocating and assigning foreign taxes to baskets and income groups?
  • What are the issues associated with foreign tax redeterminations and methods to overcome them?
  • What is the impact of proposed Sections 1.861-20 and 1.1502-4?
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