Maximizing Foreign Tax Credits: Planning and Compliance (Currently Unavailable)

Author: Robert J. Misey

Help eliminate the double taxation issues your individual U.S. taxpayer or U.S.-based multi-national company clients face when earning income abroad by gaining a full understanding of the foreign tax credit options available and how to file their respective forms.

This insightful two-hour CPE course, presented by international tax and business practitioner and teacher, Robert J. Misey, Jr., LL.M., J.D., M.B.A., will provide a practical analysis of the foreign tax credit with helpful tips on how U.S. businesses can use the credit and file Form 1116 or Form 1118 to mitigate the effects of double taxation.

Master Foreign Tax Credit Fundamentals
Mr. Misey will review the essential concepts, rules and requirements necessary to properly advise U.S. taxpayers with respect to taking a foreign tax credit.

Publication Date: August 2017

Designed For
Essential for all practitioners who deal with cross-border tax compliance and planning issues — and is especially important today as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area. Professionals in public practice and in industry will benefit from this program.Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys and financial advisors who work with and advise businesses and individuals that have cross-border operations, activities and issues.

Topics Covered

• Creditability of foreign taxes
• Difference between direct and deemed paid foreign tax credits
• Sourcing rules and how the sourcing rules limit the ability to credit foreign taxes
• Strategies for eliminating excess foreign tax credits
• Substantiation requirements for proof of foreign income taxes paid
• Preparing Form 1116 and the Form 1118
• How to determine the creditability of a foreign tax
• The difference between the direct foreign tax credit and the deemed paid foreign tax credit
• Basket limitations for passive limitation income and general limitation income
• How to complete the Form 1116 and the Form 1118

Learning Objectives

• Obtain a comprehensive understanding of the foreign tax credit and how it works
• Identify opportunities where the foreign tax credit can eliminate double taxation on foreign source income
• Recognize the substantiation and compliance requirements for claiming foreign tax credit with Form 1116 and Form 1118
• Identify the steps in the framework analysis for every foreign tax credit
• Differentiate which foreign tax credit is also referred to as the deemed paid credit
• Identify requirements with respect to the predominate character of the foreign levy
• Recognize and apply the formula for computing the foreign tax credit limitation
• Describe which IRS Form is used to determine the foreign tax credit
• Recognize which formula is used with respect to sourcing manufactured inventory
• Identify special sourcing rules
• Differentiate foreign tax credits and how they correlate to IRC sections
• Describe passive basket income

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of U.S. federal taxation of international transactions and businesses.

Advance Preparation
None