And the BEAT Goes On: Proposed Regulations Address Numerous Issues

    View Authors December 2018

    The US Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations to implement Section 59A of the Internal Revenue Code, the Base Erosion and Anti-Abuse Tax (BEAT). That provision, enacted as part of the Tax Cuts and Jobs Act, is intended to protect the US federal corporate income tax base from being eroded by tax-deductible payments made by certain large US corporate taxpayers to foreign affiliates by imposing a minimum tax regime.

    The regulations clarify a number of important issues with respect to the calculation and application of the BEAT and will be of interest to any multinational enterprise with US operations. In addition, Treasury and the IRS have requested comments on a number of issues raised by the proposed regulations.