This session, from TEI’s 2025 International Tax Course, provides tax professionals with a foundational understanding of the rules governing the U.S. foreign tax credit. Participants will explore the types of foreign taxes that qualify for credit, the limitations imposed on claiming the credit, and the complexities introduced by the Tax Cuts & Jobs Act.
Learning Outcomes
- Understand the basic concepts of subpart J, including section 986(c) on previously taxed earnings and profits (PTEP) distributions, and their relevance to foreign currency issues.
- Analyze the tax implications of section 987 foreign currency translation and section 988 foreign currency transactions.
- Assess the impact of the proposed section 987 regulations on the treatment of foreign currency gains and losses for tax purposes.
Who Should Attend
This session is designed for tax professionals involved in international tax matters, those transitioning to a new tax practice area within their company, or those taking on new responsibilities, including tax advisors, corporate tax professionals, CPAs, tax managers, and international tax lawyers. It will benefit professionals seeking a foundational understanding of key foreign currency tax provisions under U.S. tax law.
Instructor(s)
Daniel Stern, Partner, Baker McKenzie LLP
Kia Waxman, Tax Partner, Baker McKenzie LLP
General Session Information
Access
Online, upon completion of the checkout process, you will be directed to our Learning Management System (LMS) for access to the session.
For member pricing, please login to tei.org
This is a digital product. With full paid access, the content will be available for one year after the purchase date.
CPE Credits
This digital product is not eligible for Continuing Professional Education (CPE) credit and includes the recording from the 2025 in-person session and the corresponding PowerPoint slides.
Length of Session
The session will take approximately 3.5 hours to complete.
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
For more information, please refer to CPE requirements and NASBA sponsorship information.
Terms & Conditions
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