This session will discuss how multinational enterprises should prepare to address the potential implementation of a per-country limit on foreign tax credits and GILTI. Both changes present planning opportunities and risks, as well as significant compliance issues.
Understand the implications of per-country limits on the FTC and GILITI
Assess what advance planning opportunities and risks are or might be available to their company
Determine the compliance issues associated with FTC and GILTI limits with the greatest impact on their company.