EFTA02448331

From: Richard Joslin Sent: Wednesday, October 12, 2016 9:27 PM To: Jeffrey E.; Brad Wechsler Cc: John Castrucci; Thomas Turrin Subject: FW: foreign tax credit Good news re foreign t=x credits — general category credits from 2015 should be carried ove= to 2016 (no carryback to 2014). One caveat and I will not put into =mail (pls call to discuss) Foreign tax credits. 1 year carryback; 10 year carryforward. Credits arise from "general category " income (ma=agement fees) or from "passive category" income (interest/ div=dends). =/p> In 2012, all carry forwa=d and current year foreign tax credits were utilized. General category credit =arryback of $456,067 from 2013 (regular tax) and $528,706 (al= min) would have been absorbed into 2012 for regular and alt min purposes.=o:p> General category credit =arryback of $490,837 from 2014 (regular tax) and $196,6=1 (alt min) would not be carried back to 2013 and would be carried over to 2015= (no capacity to absorb in 2013 for regular and alt min p=rposes). All passive category cre=its were utilized in 2013 and 2014. Any unused passive category credit of $143,307 from 2015 would be carried back and absorbed in 2014 (lost if not c=rried back) Unused general category =redit of $1,881,188 from 2015 would not be carried back to 2014 and would be carried over to 2016 &n=sp; Carryover credit from 2014 would be carried over to 2016.=/o:p> =1p> =1p> Regular tax (2012): Alt min (2012): EFTA_R1_01545979 EFTA02448331 Regular tax( 2013) Regular tax (2013) — general category — =ull use (no capacity to absorb carryback) Regular tax (2013) — passive category (capacit= to absorb carryback passive category credit) Alt min (2013) - full use of general category =redit AMT 2013 ( capacity to absorb carryback fo passive c=tegory tax credits) Regular tax 2014 General category bucket — fully utilized NO ca=acity to absorb carry back 2 EFTA_R1_01545980 EFTA02448332 Regular tax 2014 Passive bucket (regular) fully use with capacity to =bsorb carryback credit AMT 2014 GENERAL CATEGORY: Capacity to absorb general categor= credit of $196,641 AMT 2014: PASSIVE CATEGORY capacity to absorb unused=passive category credits = 1, 3 EFTA_R1_01545981 EFTA02448333