The recent final foreign tax credit regulations have introduced a number of changes to the calculation of the foreign tax credit limitation. With changes to R&D tax credit expense allocation and stewardship, as well as new branch basket and loss limitation rules, there’s been a lot of regulation updates for organizations to keep up with. Additionally, final GILTI and Subpart F coordination regulations have provided a clearer picture of how to calculate the high-tax exception, but also created traps for the unwary.During this webinar, our international tax experts will address the most significant aspects of these regulation changes, their most frequently received questions, and examples to help ensure you’re following these updates accurately.
Learning objectives:
- Define specific rule changes to allocations of R&D, stewardship, and interest expense allocations.
- Determine the differences in treatment of intercompany payments in branch basket rules between sourcing and basketing of foreign source income.
- Understand necessary separate loss limitation tracking and impact on creditability.
- Understand GILTI and Subpart F coordination provisions, particularly regarding the high-tax exception and its impact on partnership- and private-equity-owned structures.
