transcript   Transcript

Foreign Tax Credits and Subpart F Planning and Developments

Recorded on: Feb. 9, 2018
Running Time: 01:31:13

Full Transcript:

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Taken from the Web Program International Tax Issues 2018 held February 2018 in New York

Foreign Tax Credits and Subpart F Planning and Developments [01:31:13]

  • Toll charge under new Section 965
  • GILTI (Section 951A) and other changes to Subpart F
  • Repeal of Section 902 and other changes to the FTC rules (i.e., new baskets)
  • Changes to interest expense apportionment and sourcing rules
  • Continued existence of Section 956 - pitfalls and planning
  • BEAT considerations for supply chains of U.S. multinationals
  • State Aid claims - creditability and supply chain planning implications

Stephen R.A. Bates,  David J. Sotos, Christopher Trump

The purchase price of this Web Program segment includes the following article from the Course Handbook available online:

  • House and Senate Tax Reform Proposals Could Significantly Impact US International Tax Rules (November 28, 2017)
    David J. Sotos

Presentation Material

  • Foreign Tax Credits and Subpart F and Developments
    Stephen R.A. Bates, David Sotos, Christopher Trump
    Christopher Trump ~ Deloitte Tax LLP
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