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April 22, 2022
2022-0665

Tuesday, May 10 | International tax talk quarterly series with the EY Global Tax Desk Network (1 pm ET)

A series addressing pertinent global tax topics and recent developments

Addressing Latin America (LATAM) and Asia-Pacific (APAC) taxes in the context of the latest US foreign tax credit (FTC) regulations

The final FTC regulations issued in January 2022 fundamentally revamped and modified the requirements for a foreign tax to be considered a creditable income tax in the United States. Among other things, the regulations prescribe that the sourcing rules for the income in the foreign jurisdiction should be reasonably similar to those of the US Internal Revenue Code in order for the taxpayer to claim a credit for foreign withholding taxes. The requirements under the rules have far-reaching implications and restrict the ability of US multinational enterprises (MNEs) to claim FTCs on a wide range of foreign taxes, including withholding taxes such as on royalties and service income.

This webcast will address how these regulations are expected to impact the ability of US MNEs to claim credits in the United States. In this context, MNEs should evaluate how they may be affected and may want to reconsider certain cross-border flows. Since this change is expected to have the most significant impact in APAC and LATAM regions, we will focus on key withholding-tax-related developments in these regions and potential business considerations. At a high level, the webcast will also consider the interplay between the US FTC regulations, US policy perspectives and implementation of the Organisation for Economic Co-operation and Development’s BEPS 2.0 initiative.

Date: Tuesday, 10 May 2022

Time: 1:00–2:15 p.m. ET New York; 10:00–11:15 a.m. PT Los Angeles

Registration: View archive here.

Panelists

  • Ana Mingramm, Global Tax Desk Network Leader, International Tax and Transaction Services, Ernst & Young LLP

  • Gagan Malik, Asia-Pacific Business Group, International Tax and Transaction Services, Ernst & Young LLP

  • JD Hamilton, Partner, International Tax and Transaction Services, Ernst & Young LLP

  • Jason Yen, Partner, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Recognize the main elements of the revised US FTC regulations; identify the tax considerations related to potential non-creditability of withholding taxes paid by US MNEs in APAC and LATAM jurisdictions; identify possible approaches to these tax considerations; recognize potential interplay with US tax policy changes due to BEPS 2.0’s “Pillar 2.” 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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