The foreign tax credit (FTC) is the primary mechanism used by the United States to mitigate double taxation on foreign-source income. Yet, many taxpayers—both individuals and corporations—are surprised to learn that foreign income taxes paid do not always result in a dollar-for-dollar credit. Complex limitation rules, sourcing principles, and substantiation requirements can significantly restrict the allowable credit, creating compliance risk and lost planning opportunities.
This comprehensive online course delivers a practical, step-by-step examination of foreign tax credit planning and compliance under current law. Led by former IRS Chief Counsel (International) attorney Robert Misey, the course explains what constitutes a creditable foreign tax, how the foreign tax credit limitation operates, and how sourcing rules—including those affecting U.S.-manufactured inventory—can materially impact credit utilization. Special attention is given to planning strategies designed to mitigate limitation constraints and maximize allowable credits.
The program concludes with a hands-on walkthrough of foreign tax credit reporting, including preparation of sample Forms 1116 (individuals) and 1118 (corporations). Designed for tax professionals advising cross-border clients or multinational operations, this course equips participants with the technical clarity and practical tools needed to confidently navigate FTC planning and compliance.
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2029 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN cardPublication Date: June 2026
Designed For
This course is designed for professionals who work with international tax issues and must accurately apply foreign tax credit rules.
Topics Covered
- Overview of the foreign tax credit framework
- Determining creditable foreign taxes
- Foreign tax credit limitation and sourcing rules
- Planning strategies to increase foreign tax credit utilization
- Impact of inventory sourcing rules on the limitation
- Foreign tax credit limitation baskets
- Substantiation and documentation requirements
- Completion of Forms 1116 and 1118
Learning Objectives
- Identify which foreign taxes qualify as creditable for purposes of the foreign tax credit
- Apply the foreign tax credit limitation rules to determine allowable credits
- Analyze how income sourcing rules affect foreign tax credit calculations and utilization
- Differentiate between the various foreign tax credit limitation baskets and their restrictions
- Explain how to substantiate creditable foreign taxes in accordance with IRS requirements
- Demonstrate how to prepare Forms 1116 and 1118 to properly report and claim the foreign tax credit
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Robert J. Misey
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.
For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.
Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm.
Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.
Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.