Overview

Understand the key concepts.

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. This course can be purchased individually or as part of the U.S.International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.

The CPE self-study course covers, in more detail, the Foreign Tax Credit (FTC) Rules and key concepts. It then focuses on key concepts of the expense apportionment rules, including general methods, alternative methods, and special rules such as "Controlled Foreign Corporation (CFC) netting."

Finally, it discusses foreign tax splitter arrangements under Section 909 and the impact of Section 901(m) on indirect paid credits.

Highlights

Key Topics

• Summary of the FTC rules
• Sections 901, 902, and 960
• Separate Basket FTC Limitations and Look-Through Rules, Separate Limitation Losses
• Overall Foreign Loss (OFL)
• Overall Domestic Loss (ODL)
• Indirect credit and lower tier subsidiaries
• Review of Section 861 rules
• Alternative allocation methods available
• CFC netting rules
• Tax book value methods
• Impact of branches on expense allocations
• Cover splitter structures and impact on FTC
• Impact from 901(m)

Prerequisites

None

Objectives

Learning Outcomes

• Identify eligible foreign tax credits
• Recognize the value of foreign tax credits
• Apply key foreign tax concepts
• Calculate foreign tax credit and limitation
• Explain some of the complexities with OFL, ODL
• Identify foreign tax credit issues in client discussions
• Understand purpose and approach of Section 861
• Explain allocation/apportionment methods available for interest, R&E, and other relevant expenses
• Calculate allocation of expenses under standard and alternative methods
• Explain impact of branches and CFC netting rule on expense allocations and apportionment
• Describe the operation of the section 909 rules
• Identify when the section 909 rules apply
• Show applicability and impact of section 901(m) and relationship to section 338 elections