The Proposed Foreign Tax Credit Regulations: Practical 2019 Compliance Guide
The Tax Cuts and Jobs Act (TCJA) of 2017 brought about sweeping changes to the determination of foreign tax credits. To address the TCJA’s impact, the Internal Revenue Service (IRS) released proposed regulations providing guidance to U.S. taxpayers claiming foreign tax credits. The regulations aim to address various issues including deductions’ allocation, identification of supposed paid credits, and transition rules for foreign loss.
The proposed tax regulations are complex and long. Taxpayers and practitioners must be in the know of the recent developments concerning the proposed rules to efficiently prepare for the potential implications.
In this LIVE Webcast, a seasoned panel of thought leaders and professionals brought together by The Knowledge Group will provide and present to the audience an in-depth analysis of the proposed IRS regulations concerning foreign tax credits. Speakers will also present the best compliance practices in light of the recent developments.
Some of the major topics that will be covered in this course are:
- The Proposed Foreign Tax Credit Regulations: An In-Depth Analysis
- Recent Developments
- Implications for Taxpayers
- Best Compliance Practices
- Maximizing Foreign Tax Credits
- What Lies Ahead
Alvarez & Marsal Taxand, LLC
Alvarez & Marsal Taxand, LLC
- Which foreign taxes are creditable: tracing foreign taxes to GILTI and other categories of CFC income.
- Expense allocation and apportionment for GILTI: exempt asset and income treatment.
- Categorizing CFC stock under the proposed Sec. 861 regulations.
- The GILTI high-tax exception and its impact on the foreign tax credit.
Who Should Attend:
- Tax Attorneys
- Tax Executives
- Tax Managers
- Financial Executives
- Tax Accountants
Kristina Dautrich Reynolds is a Managing Director with Alvarez & Marsal Taxand in Washington, D.C., advising corporate clients on both inbound and outbound international tax matters.
Ms. Reynolds has served clients across such industries as financial services, energy, manufacturing and real estate. Her experience includes international restructuring, annual reporting, acquisition and disposition planning.
Prior to joining A&M, she spent nearly six years in public accounting. Most recently, she was a manager with the international tax services group of Deloitte Tax. Previously, she was with the corporate tax practice of Arthur Andersen in Washington, D.C.
Ms. Reynolds earned a bachelor's degree in accounting from Salisbury State University and a master's degree in accounting, with a concentration in taxation, from the George Washington University. She is a Certified Public Accountant (CPA) in Maryland and Virginia, and a member of the American Institute of Certified Public Accountants and the Maryland Association of Certified Public Accounts.
Kristina Dautrich Reynolds is a Managing Director with Alvarez & Marsal Taxand in Washington, D.C., advising corporate clients on both …
Brendan Sinnott is a Director in the International Tax practice of Alvarez & Marsal Taxand, LLC. Mr. Sinnott advises multinational corporations on the U.S. tax implications of global transactions.
Mr. Sinnott serves clients across industries such as telecommunications, professional services, web-based services, manufacturing. Additionally, Mr. Sinnott’s areas of expertise include permanent establishment planning, cross-border transactions, foreign tax credit analysis, Subpart F planning, inbound financing, & international compliance.
Mr. Sinnott advises closely-held, publicly traded, and PE portfolio companies, and works closely with CFOs and VPs of tax in identifying ownership’s needs in developing tax and cash planning strategies.
Mr. Sinnott earned a master’s of Science in Taxation and a bachelor’s Degree in Accounting from the University of Miami. He is a licensed CPA in New York.
Brendan Sinnott is a Director in the International Tax practice of Alvarez & Marsal Taxand, LLC. Mr. Sinnott advises multinational …
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Method Of Presentation:
On-demand Webcast; Group-Internet Based
General knowledge of tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
1.0 CLE; 1.0 NASBA-CPE
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About Alvarez & Marsal Taxand, LLC
In 1983, Tony Alvarez and Bryan Marsal joined forces to create A&M. They believed then, as the firm still does now, that operational excellence is the heartbeat of growth for every company. The founding principles of leadership, action and results remain at the core of A&M.
A&M Taxand’s multi-disciplinary tax service teams provide full-service, integrated tax services, from tax planning, to tax compliance and financial reporting. Our professionals provide tax advisory services to mid-market, larger corporate, global and U.S. based clients without audit-based conflicts of interest
We turn responsiveness into results. Our focus is on you and our tax advisory practice has a strategy that will help your company succeed. From planning with international tax consultants to navigating local laws, our tax professionals have a distinguished track record for working with major companies and their investors to address complex tax issues.
We understand domestic and international tax environments. But more importantly, we work diligently to understand your business, your challenges, your goals, and your needs. Together with our global partners, we strive for a common goal: practical advice, responsibly delivered.