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October 7, 2020
2020-2418

Thursday, October 15 | Proposed foreign tax credit regulations would add new requirements, election (1 pm ET)

Please join our panelists for an in-depth discussion of recently released proposed foreign tax credit (FTC) regulations (REG-101657-2). Topics to be discussed include:

  • New jurisdictional nexus requirement for determining whether a credit is allowed for a foreign income tax
  • Rules for allocating and apportioning foreign income taxes paid with respect to certain disregarded transactions
  • Identifying foreign income taxes for which a credit and deduction are denied under IRC Section 245A(d)
  • A new election to capitalize and amortize research and experimentation (R&E) and advertising expenditures for purposes of apportioning interest expense

Date: Thursday, 15 October 2020

Time: 1:00-2:00 p.m. EDT New York; 10:00-11:00 a.m. PDT Los Angeles

Registration: View archive here. go to Proposed foreign tax credit regulations

Panelists

Marjorie Rollinson, Deputy Leader — National Tax Department, Ernst & Young LLP

Doug Bailey, Partner, International Tax and Transaction Services — National Tax Department, Ernst & Young LLP

Martin Milner, Principal, International Tax and Transaction Services — National Tax Department, Ernst & Young LLP

Colleen O'Neill, Partner, International Tax and Transaction Services — National Tax Department, Ernst & Young LLP

Moderator

Jose Murillo, Director — International Tax and Transaction Services — National Tax Department, Ernst & Young LLP

CPE credit offered: up to 1.2 depending on actual duration. Recommended field of study: Taxes. Learning objective: Discuss the recently released proposed FTC regulations and how they may affect your business. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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