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January 5, 2022
2022-0013

Thursday, January 13 | Understanding the latest FTC regulations (1 pm ET)

What changed, what stayed the same and what actions to consider

The release of final foreign tax credit (FTC) regulations on December 28, 2021 could significantly restrict taxpayers’ ability to claim certain FTCs.

Join our panel of international tax professionals for an in-depth discussion of the final regulations, including what changed compared to the proposed FTC regulations issued in 2018, what stayed the same and what actions taxpayers may want to consider. Specific topics to be addressed include:

  • The definition of a foreign income tax and a tax in lieu of an income tax, including the new “attribution requirement” (known as the “jurisdictional nexus requirement” under the proposed regulations)
  • Rules for allocating and apportioning foreign income taxes relating to disregarded payments and certain other transactions
  • Disallowance of a credit or deduction for certain foreign income taxes
  • When foreign taxes accrue

We hope you will be able to join us.

Date: Thursday, January 13, 2022

Time: 01:00 PM Eastern Standard Time

Registration: View archive here.

Panelists

  • Colleen O’Neill, Director of International Tax and Transaction Services, National Tax Department, Ernst & Young LLP

  • Stephen Bates, Principal, International Tax and Transaction Services, Ernst & Young LLP

  • Ray Stahl, Principal, International Tax and Transaction Services, Ernst & Young LLP

  • Aaron Topol, US-Central Region International Tax and Transaction Services Leader, Ernst & Young LLP

Moderator

  • Craig Hillier, EY Americas International Tax and Transaction Services Leader

CPE credit offered: up to 1.2 depending on duration. Recommended field of study: Taxes. Learning objectives: Define a foreign income tax under the regulations, identify the requirements that the tax must meet to be creditable, recognize how to allocate and apportion foreign income taxes, and identify when a credit or deduction for a foreign tax may be disallowed. 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. 

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The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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