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Treasury and the IRS on December 2, 2019, released 343 pages of final regulations and 59 pages of proposed regulations for the Base Erosion and Anti-Abuse Tax (BEAT) under Section 59A as enacted by the 2017 tax reform legislation. The BEAT rules require certain corporations to pay a minimum tax on taxable income as computed without deductions for certain payments to foreign related parties. This Insight lists some of the key highlights we have identified thus far.

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