Overview of Foreign Tax Credit

Foreign tax credits: An end-to-end education

The foreign tax credit is a powerful tool for U.S. businesses that earn foreign-sourced income. This course provides a detailed explanation of the many aspects of the foreign tax credit, including:

• Computation
• Limitation determination
• Carryover rules
• Allocation and apportionment
• Splitting events and splitter arrangements

Updated for the latest in foreign tax credit regulations

This course has been updated for U.S. guidance, including final regulations and notices, and the interaction with Pillar 2 of the Organisation for Economic Co-operation and Development (OECD) base erosion and profit shifting (BEPS) project.

Part of a comprehensive international tax education

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation.

This course can be purchased individually or as part of the U.S. International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Key Topics

• Foreign tax credit rules
• FTC baskets
• Direct and indirect FTCs
• Separate limitation losses
• Splitting events and splitter arrangements
• Covered asset acquisitions

Learning Outcomes

• Recall the general foreign tax credit (FTC) rules.
• Identify eligible foreign tax credits.
• Determine the FTC mechanics and limitations.
• Identify separate limitation baskets and computations.
• Distinguish between the direct and indirect FTCs.
• Recall the complexities of separate limitation losses (SLL), overall domestic losses (ODL), and overall foreign losses (OFL).
• Recognize foreign tax credit (FTC) splitting events.
• Identify prescribed regulatory FTC splitter arrangements.