Layla Asali and Rocco Femia will speak at the George Washington University Law-Internal Revenue Service 34th Annual Institute on Current Issues in International Taxation on December 14, 2023, in Washington, DC.

Asali will present, as part of a panel, "Foreign Tax Credits - 'Can You Actually Get a Credit?'" Topics will include:

• Treasury Regulations Sections 1.861-20 and 1.960-1, including the rules related to "contributions" to branches and a comparison of the treatment of taxes imposed on disregarded and regarded distributions, with the latter focusing on distortions caused by the asset method for  assigning taxes imposed on disregarded distributions, the consequences  of not linking disregarded distributions to PTEP, and complications caused by the proliferation of groupings
• CAMT and foreign tax credits, including under Notice 2023-64
• The FedEx case and Sysco petition 

Femia will present, as part of a panel, "PTEP, Repatriation of Earnings, and Anti-Deferral (GILTI/Subpart F)." Topics will include:

• PTEP updates, including AM 2023-002
• GILTI & Subpart F current developments, including final Treasury Regulations Section 1.1502-80(j)
• Section 367(d) proposed regulations
• Selected Section 245A and CAMT issues
• Pillar 2 interactions with US anti-deferral regime and transitional safe harbor
• Selected PFIC issues