OB3 Impacts: Foreign Tax Credit Changes
November 19, 2025Join the International Tax team from Forvis Mazars for sessions focused on new legislation from the One Big Beautiful Bill Act (OB3 or OBBBA) impacting multinational enterprises (MNEs). These informative presentations are designed to deepen technical understanding and provide practical planning insights for CFOs, VPs of tax, tax directors, controllers, and those seeking to learn more about OB3.
Our third session will cover the new Foreign Tax Credit (FTC) basket rules, standards of what is creditable, and the impact of treaty-based sourcing and hybrid arrangements. We’ll also explore planning considerations for carryforwards and disallowed credits, along with the interplay between these rules and domestic provisions, such as bonus depreciation and Sections 174 and 163(j), foreign branch rules, check-the-box (CTB) elections, Base Erosion and Anti-Abuse Tax (BEAT), and the branch FTC. An in-depth case study will tie these elements together to illustrate their real-world applications.
Learning Objectives
Upon completion of this program, participants will be able to:
- Discuss the new FTC basket rules and the standards of what is now considered creditable.
- Identify planning opportunities for managing carryforwards and disallowed credits.
- Analyze the interaction between FTC rules and key domestic provisions.