This program will discuss the foreign tax credit "legal liability" regulations issued under section 901. The panelists will also describe the relevant features of various consolidated group systems outside the US. They will discuss the application of the new regulations to each such consolidated group fact pattern. 

Moderators:         Friedhelm Jacob, Hengeler Mueller, Frankfurt, Germany

                                Rebecca Rosenberg, Caplin & Drysdale Chartered, Washington, DC

Panelist:                Bethany Ingwalson, Senior Counsel, Branch 3, Office of Associate Chief Counsel (International), Washington, DC

Sponsored by:      Foreign Activities of US Taxpayers and Foreign Lawyers Forum