The US Internal Revenue Service today issued proposed regulations on the new base erosion and anti-abuse tax (BEAT).
The regulations implement section 59A, added in the Tax Cuts and Jobs Act (TCJA), passed in December 2017, which imposes an additional tax on companies that make deductible payments to foreign related parties.
According to an IRS release, the proposed regulations provide detailed guidance regarding which taxpayers will be subject to section 59, the determination of what is a base erosion payment, the method for calculating the base erosion minimum tax amount, and the required base erosion and anti-abuse tax resulting from that calculation.
This is breaking. MNE Tax analysis to follow…
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