Name
International Taxation: Conceptualizing an FTC Rethink: How to Improve Your Credit (Rules)
Speakers
Michael Caballero, Covington & Burling LLP
Paul Oosterhuis, Skadden, Arps, Slate, Meagher & Flom LLP
Danielle Rolfes, KPMG LLP
Paul Oosterhuis, Skadden, Arps, Slate, Meagher & Flom LLP
Danielle Rolfes, KPMG LLP
Date & Time
Wednesday, January 13, 2027, 2:30 PM - 3:45 PM
Description
A more conceptual conversation: with expense allocation, the Section 904 baskets, the NCTI credit haircut, sourcing, and the Pillar Two overlay all piling up, how might the foreign tax credit actually be redesigned? What a cleaner, more administrable credit could look like — and what it would take to get there.
