The Internal Revenue Code has long permitted U.S. taxpayers to take a dollar-for-dollar credit against their taxes for qualifying taxes paid to foreign governments and localities, known as the foreign tax credit (FTC). For years, the FTC focused on certain types of income taxes, but recent IRS regulations have called into question many of the assumptions that have driven the calculation of the credit for U.S. businesses paying taxes overseas.The updated regulations have changed what qualifies as a creditable tax, along with some additional changes that limit the ability to take the credit. Our international tax experts will walk through these changes and discuss what taxpayers need to know to stay up to date.
Learning objectives:
- Identify taxes that are eligible for the foreign tax credit (FTC)
- Understand the 901 cost attribution and cost recovery rules, and the 903 withholding tax requirements
- Develop some next steps an organization can take to help ensure its international tax plans are up to date
