The US Internal Revenue Service on December 14 published five “practice units” describing the rules applicable to the base erosion and anti-abuse tax (BEAT) and other international tax topics, interest on deferred tax liability, and tax shelter promoters.
IRS practice units are internal training decks developed for agency employees.
The practice unit on interest on deferred tax liability reviews requirements under Internal Revenue Code section 453A for a seller who reports gain on the installment method of accounting to pay interest on the deferred tax liability. It covers how to determine the deferred tax liability, underpayment rate, and interest due.
The BEAT practice unit provides an overview of the tax imposed under IRC 59A on applicable large taxpayers that make certain base erosion payments to foreign related parties. It describes the statutory and regulatory provisions, sets out examples, and highlights relevant reporting forms.
The other international practice units cover the effect of flow-through entities on an individual’s foreign tax credit and treaty exemptions for nonresident alien students and teachers.
The final practice unit reviews procedures for investigations of tax shelter promoters.
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