transcript   Transcript

Foreign Tax Credits and Subpart F Planning and Developments

Recorded on: Feb. 8, 2017
Running Time: 01:34:02

Full Transcript:

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Taken from the Web Program International Tax Issues 2017 recorded February, 2017 in New York.

Foreign Tax Credits and Subpart F Planning and Developments [01:34:02]
  • State Aid claims – creditability and supply chain planning implications
  • Section 909 splitter regulations 
  • Section 901(m) covered asset acquisitions
  • Regulations on active rents and royalties
  • Subpart F sales & services income 
  • Defending substantial contribution

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

  • IRS Provides Roadmap for Examining Subpart F Foreign Base Company Income Functional Analysis (February 19, 2016)
    David J. Sotos
  • EU Fiscal State Aid—A Briefing Document (October 15, 2014)
    David J. Sotos
  • Foreign Tax Credit Guidance under Section 909 Related to Foreign-Initiated Adjustments; Notice 2016-52
    David J. Sotos
  • Notice 2016-52 Details Section 909 Regulations for FTC Splitting Events Arising from Foreign-Initiated Adjustments Such as EU State Aid (September 19, 2016)
    David J. Sotos

Presentation Material

  • Foreign Tax Credits and Subpart F Planning and Developments
    Stephen R.A. Bates, Gretchen T. Sierra, David Sotos
Gretchen T Sierra ~ Deloitte Tax LLP
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