Thursday, August 22, 2019

Tomorrow: Foreign Tax Credit Limitations Under Section 904: Guidance for Tax Counsel and New IRS Regulations

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Foreign Tax Credit Limitations Under Section 904: Guidance for Tax Counsel and New IRS Regulations
August
 
23
3 pm - 4:15 pm ET
Presenter: Neel Modha, of Holthouse, Carlin & Van Trigt LLP
Credits: CPE, IRS EA, CLE in all states (Credit Details)
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Course Description
 

In this practical webinar, you will learn about:

  • How to calculate the foreign tax credit
  • The different baskets of the foreign tax credit
  • The changes in the foreign tax credit rules set forth in the 2017 Tax Cuts and Jobs Act

Upon course completion, you will be able to:

  • Describe the foreign tax credit limitation
  • Differentiate between a credit and a deduction
  • Identify the sourcing rules to source gross income
  • Outline the basic rules for allocating expenses
  • Identify the baskets used in the FTC analysis, including the new GILTI and Foreign Branch Income Baskets
  • Identify the documentation necessary to claim the foreign tax credit
  • Describe the carryforward and carryback rules before and after
  • Examine deemed paid foreign taxes under IRC section 960
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The Presenter
About The Presenter
 
Neel Modha is a Senior Tax Manager of the International Tax Team at the CPA firm, Holthouse, Carlin & Van Trigt LLP in the Irvine, California office. Mr. Modha is an experienced tax adviser, focusing on international tax consulting and compliance services. He works on a variety of international tax issues that affect individuals, corporations, and partnerships. Mr. Modha is licensed to practice law in New York and Connecticut and is a graduate of LL.M. in Taxation program from Northwestern University School of Law.
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