Recent proposed regulations offer limited relief for certain foreign tax credit related issues, softening the cost-recovery requirements and providing for relief for royalty withholding taxes. Our international tax team will review the highlights of the proposed regulations and provide you practical insights into how your business may be impacted. In addition, our team will discuss the state of the OECD’s two-pillar program and other recent international tax developments. 

Learning objectives:

• Demonstrate a working knowledge of the 2022 proposed foreign tax credit regulations, as well as other recent international tax developments 
• Analyze developments and guidance to determine their effects on your organization
• Determine how these developments would apply under certain facts and circumstance and assess the impact