News & Analysis as of

Base Erosion Tax Internal Revenue Service

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Eversheds Sutherland (US) LLP

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

McDermott Will & Emery

Weekly IRS Roundup November 29 – December 3, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 29, 2021 – December 3, 2021... November 29, 2021: The IRS published a news release...more

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

Weekly IRS Roundup August 10 – August 14, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

Alston & Bird

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

Alston & Bird on

Our International Tax Group analyzes some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax....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

McDermott Will & Emery

IRS Announces More LB&I Campaigns!

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The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

McDermott Will & Emery

Weekly IRS Roundup March 4 – 8, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4 – 8, 2019....more

Fenwick & West LLP

Treasury and IRS Propose Welcome (and Some Unwelcome) Guidance on the Base Erosion and Anti-Abuse Tax

Fenwick & West LLP on

Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT). In general, the guidance is reasonably consistent with the statute...more

Proskauer - Tax Talks

The Proposed BEAT Regulations

Proskauer - Tax Talks on

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse...more

Eversheds Sutherland (US) LLP

And the BEAT goes on – proposed regulations clarify the application of the base-erosion and anti-abuse tax

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as...more

McDermott Will & Emery

Proposed BEAT Regulations | Tax-Free Transactions May Give Rise to a Liability

McDermott Will & Emery on

On December 13, 2018, US Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations for the Base Erosion and Anti-Abuse Tax (the BEAT), which was added to the Code as part of the 2017 Tax...more

A&O Shearman

Base Erosion and Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations

A&O Shearman on

On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Bracewell LLP

Bracewell Tax Report: February 2018

Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Foley & Lardner LLP

BREAKING NEWS: Congress Sends Tax Cuts and Jobs Act to President Trump’s Desk for Signing

Foley & Lardner LLP on

The Tax Cuts and Jobs Act (TCJA) has been passed by both houses of Congress and is now set to be signed into law by President Trump. The vote was 224-201 in the House with all the Democrats joined by twelve Republicans voting...more

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