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Treasury Drops the BEAT—Final Base Erosion and Anti-Abuse Tax Regulations
11 December 2019
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Treasury and the IRS have released Final and Proposed Regulations on the base erosion and anti-abuse tax (BEAT) introduced in 2017 tax reform legislation.
The Final Regulations, which are now in effect, apply the BEAT in an inflexible way to a number of transactions between U.S. taxpayers and their foreign affiliates.
The Final Regulations do not provide relief that taxpayers had requested for offsetting transactions between related taxpayers (netting). The BEAT will apply to those transactions on a gross basis.
The Proposed Regulations include a helpful waiver rule allowing taxpayers to permanently give up tax deductions in order to avoid becoming subject to the BEAT.
Gary M. Friedman
Peter A. Furci
Peter F.G. Schuur
Lillian Jo Aston
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