News & Analysis as of

Base Erosion Tax Anti-Abuse Rule

Eversheds Sutherland (US) LLP

Say hello to the BEAT waiver: Final regulations adopt and clarify prior proposed regulations

The ability of taxpayers to waive deductions in order to ensure that they are not subject to the base-erosion and anti-abuse tax (BEAT) was confirmed in final regulations under section 59A issued on September 1, 2020 (Final...more

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Emery on

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

Fenwick & West LLP

Final and Proposed New BEAT Regulations Contain Important Changes

Fenwick & West LLP on

The final Base Erosion and Anti-Abuse Tax regulations recently approved in T.D. 9885 generally follow the December 21, 2018, proposed regulations with a few important changes. The IRS also issued new proposed regulations at...more

A&O Shearman

Treasury and IRS Issue Final Regulations on Base Erosion and Anti-Abuse Tax (The BEAT)

A&O Shearman on

On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more

Carlton Fields

Tax Reform: Insurance Company Provisions

Carlton Fields on

Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry....more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Insurance Companies

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

McDermott Will & Emery

US Tax Reform Measures Affecting Foreign Multinationals

McDermott Will & Emery on

On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more

Baker Donelson

Tax Overhaul Draws New Boundaries Around International Business

Baker Donelson on

The newly passed tax legislation significantly alters the landscape for international business. The final Republican tax cut bill moves the U.S. from a so-called "global taxation regime" to a territorial taxation regime in...more

McDermott Will & Emery

The Senate’s New Base Erosion Tax: Highlights for Renewable Energy

McDermott Will & Emery on

On December 2, 2017, the Senate approved its version of the Tax Cuts and Jobs Act. The Senate Bill includes the base erosion and anti-abuse tax, a new tax intended to apply to companies that significantly reduce their US tax...more

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