News & Analysis as of

Proposed Regulation Base Erosion and Anti-Abuse Tax (BEAT)

McDermott Will & Emery

Five Things a CFO of a Recently De-SPAC’ed Company Should Know About the Biden Made in America Tax Plan

McDermott Will & Emery on

CFOs of recently de-SPAC’ed* and newly public companies face significant challenges. High on the list is the recently released Made in America Tax Plan, through which the Biden administration proposed significant changes to...more

McDermott Will & Emery

Government Releases Second Tranche of Final Regulations on BEAT

McDermott Will & Emery on

On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...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

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

Eversheds Sutherland (US) LLP

Changing the BEAT - Final regulations answer key questions, proposed regulations give new relief

A year after the initial proposed BEAT regulations were released, Treasury and the IRS have issued a package of final and proposed regulations under § 59A of the Internal Revenue Code of 1986, as amended (the Code), the...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

Weekly IRS Roundup December 2 – 6, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

A&O Shearman

Section 385 Treasury Regulations Developments

A&O Shearman on

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Latham & Watkins LLP

Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

Latham & Watkins LLP on

The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability. Key Points: The base erosion and anti-abuse tax (BEAT) proposed regulations: ...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

McGuireWoods LLP

Key Takeaways From the BEAT Proposed Regulations

McGuireWoods LLP on

On Dec. 13, 2018, the Internal Revenue Service and Department of Treasury issued proposed regulations addressing the base erosion and anti-abuse tax (BEAT). In general, the regulations provide guidance for identifying an...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

BEAT, FATCA and Insurance - proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under...

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more

BakerHostetler

High-Level Summary of BEAT Provision

BakerHostetler on

The Treasury Department and the IRS published proposed regulations yesterday on the Base Erosion and Anti-Abuse Tax (BEAT) that was enacted by the Tax Cuts and Jobs Act of 2017. ...more

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