Overview
Damon Lyon will speak on the panel entitled, “Foreign Tax Credit & Subpart F Developments and Planning” at PLI’s International Tax Issues 2018.
Topics Include:
- GILTI (Section 951A)
- Foreign tax credits under TCJA: Section 902 repeal, new Section 960, and the new Section 904 baskets
- Changes to the expense apportionment rules
- Continued existence of Section 956 – pitfalls and planning
- IRS regulations update