Treasury and IRS Release Final and Proposed BEAT Regulations

On December 2, the Treasury and the IRS released final and proposed regulations under section 59A. Section 59A imposes a base erosion and anti-abuse tax (or BEAT), which generally operates as a minimum tax on income without regard to certain deductible payments made to foreign related parties. The final regulations implement BEAT generally, and the proposed regulations provide guidance with respect to the determination of a taxpayer’s aggregate group, provide an election to waive deductions, and detail application of BEAT to partnerships.


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