Content Provider
Rimon logo
Sponsored by
Netsuite logo
Handout Materials
Presentation Slides
Additional Materials
Webinar Technical FAQs
Free cpece webinars
Basics of Foreign Tax Credits

BASICS OF FOREIGN TAX CREDITS

Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 31, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

United States taxpayers with multinational activities face potential exposure to double taxation - from the source country for the income item and the United States as their country of residence. Most often, the method to avoid double taxation from a residence country perspective is foreign tax credit utilization. This program will cover primary considerations in the context of the United States foreign tax credit system, including recent modifications to the system. We'll also discuss general considerations for double taxation purposes before delving into the FTC in detail, covering baskets for income items and offset opportunities. Lastly, we will talk about considerations to ensure tax credit availability is not mistakenly removed.

Learning Objectives:


  • Determine primary considerations in the context of the United States foreign tax credit system

  • Summarize general considerations for double taxation purposes before delving into the FTC in detail

  • Recall considerations to ensure tax credit availability is not mistakenly removed

Not logged
PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
Linkedin
Rimon logo

Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.


Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.


Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.


Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.


User-added image

 

About Our Presenter

Rimon logo
Rimon is a highly selective entrepreneurial firm that combines the dynamic client service, teamwork, and agility of a high-end boutique law firm with the deep multidisciplinary experience of a large global firm. Our clients consistently receive exceptional representation across twelve countries and five continents, from our all-star team of corporate, litigation, tax, intellectual property, entertainment, and private client attorneys.

Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.

Rimon’s clients range from cutting-edge technology startups to financial institutions and Fortune 100 companies.

Rimon's attorneys come with decades of experience before even joining Rimon. Rimon's attorneys were meticulously drawn from the top ranks of premier law firms, international corporations, and academia. They hold JDs, PhDs, LLMs, and MBAs from the best universities in the United States and abroad. They have worked on multi-billion dollar deals, have won bet-the-company litigation, and have run universities. Their experience and education ensure our clients receive consistently excellent and comprehensive counsel.