Overview of Foreign Tax Credit

Overview

A comprehensive education of the popular tax credit, including its computation, limitations, and complexities.

Highlights

Key Topics

• Foreign tax credit rules
• FTC baskets
• Direct and indirect FTCs
• Separate limitation losses
• Splitting events and splitter arrangements
• Covered asset acquisitions

Prerequisites

Basic knowledge of U.S. federal income taxation

Designed For

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• Recall the general foreign tax credit (FTC) rules.
• Identify eligible foreign tax credits.
• Determine the FTC mechanics and limitations.
• Identify separate limitation baskets and computations.
• Distinguish between the direct and indirect FTCs.
• Recall the complexities of separate limitation losses (SLL), overall domestic losses (ODL), and overall foreign losses (OFL).
• Recognize foreign tax credit (FTC) splitting events.
• Identify prescribed regulatory FTC splitter arrangements.